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Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
Regulated Asbestos Contaminated Soil Standard Operating Procedure
For City and County of Denver
Prepared by the Denver Department of Public Health and Environment
Environmental Quality Division
May 2, 2019
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
i
Table of Contents
1. Introduction .......................................................................................................................................... 1
1.1 Purpose ......................................................................................................................................... 1
1.2 Applicability ................................................................................................................................... 2
1.3 Non-RACS vs. RACS ....................................................................................................................... 3
1.4 Project-specific Regulated Asbestos Contaminated Soil Management Plan ................................ 3
1.5 Key Parties and Responsibilities .................................................................................................... 3
2. Process Flow and Decision Scenarios .................................................................................................... 6
2.1 Scenarios ....................................................................................................................................... 6
2.1.1 Excavation in Areas with No Debris ...................................................................................... 6
2.1.2 Excavation in Areas with Non-Suspect Debris ...................................................................... 6
2.1.3 Discovery of Suspect Debris or Suspect RACS During Excavation ......................................... 6
2.1.4 Excavation in Areas with Known RACS .................................................................................. 7
2.1.5 Subsurface Investigations ..................................................................................................... 7
3. General Requirements ........................................................................................................................ 13
3.1 Training for Site Personnel .......................................................................................................... 13
3.2 Health and Safety ........................................................................................................................ 14
3.3 CABI and AMS Requirements ...................................................................................................... 14
3.4 Contractor Requirements ........................................................................................................... 16
3.5 Notifications ................................................................................................................................ 17
3.6 Soil Reuse .................................................................................................................................... 18
4. Debris Identification ............................................................................................................................ 19
4.1 Debris Classified as Non-Suspect for ACM .................................................................................. 19
4.2 Debris Classified as Suspect for ACM .......................................................................................... 20
5. Initial Actions and Stabilization for RACS Discovery ........................................................................... 21
5.1 Temporary Stabilization Procedures ........................................................................................... 22
5.1.1 Horizontal Excavation Faces (Excavation Floors) ................................................................ 22
5.1.2 Vertical Excavation Faces (Excavation Side Walls or Trenches) .......................................... 22
Environmental Quality Division Denver Department of Public Health & Environment
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5.1.3 Standard Requirements for Temporary Sub-Surface Stabilization of RACS. ...................... 22
5.1.4 Standard Requirements for Permanent Stabilization of RACS ........................................... 23
5.1.5 Standard Requirements to Stabilize Investigation-Derived Waste ..................................... 23
5.2 Site Access Control ...................................................................................................................... 25
6. Suspect Asbestos Bulk Sampling ......................................................................................................... 26
7. RACS Management ............................................................................................................................. 27
7.1 Hand Removal ............................................................................................................................. 27
7.2 Mechanical Removal ................................................................................................................... 28
7.2.1 Establishing a RWA after Confirmed Discovery of RACS ..................................................... 29
7.2.2 Engineering Controls ........................................................................................................... 29
7.2.3 RACS Disposal Procedures .................................................................................................. 30
7.2.4 Wind Speed Monitoring ...................................................................................................... 33
7.2.5 Air Monitoring ..................................................................................................................... 34
7.2.6 RACS Stockpiling .................................................................................................................. 37
7.2.7 Decontamination Procedures ............................................................................................. 39
7.2.8 Work Area Clearance .......................................................................................................... 40
8. Close-Out Report................................................................................................................................. 41
9. References .......................................................................................................................................... 42
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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Figures
Figure 1 Excavation in Areas with No Debris ......................................................................................... 8
Figure 2 Excavation in Areas with Non-Suspect Debris ......................................................................... 9
Figure 3 Discovery of Suspect Debris or Suspect RACS During Excavation .......................................... 10
Figure 4 Excavation in Areas with Known RACS ................................................................................... 11
Figure 5 Subsurface Investigations ...................................................................................................... 12
Tables
Table 1 Key Parties and Responsibilities ................................................................................................... 4
Table 2 Responsibilities ............................................................................................................................ 5
Table 3 Removal/Disturbance (by hand or hand-held tools) of Non-Friable RACS ................................. 34
Table 4 Removal/Disturbance (by hand or hand-held tools) of Friable RACS ......................................... 34
Table 5 Removal/Disturbance by Mechanical Means (Heavy Equipment) of Non-Friable RACS ............ 35
Table 6 Removal/Disturbance by Mechanical Means (Heavy Equipment) of Friable RACS .................... 35
Appendices
Appendix A
Appendix B
Appendix C
Appendix D
CDPHE Approval Letter
CABI Work Day Documentation Form
Notification of Planned Soil Disturbing Activity
Sample Collection Protocols and Analytical Methodologies
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Acronyms Acronym Definition
ACM Asbestos-containing Material
AHERA Asbestos Hazard Emergency Response Act
AMS Air Monitoring Specialist
AOC Area of Contamination
AQCD Air Quality Control Division
BDL Below Detection Limits
BMP Best Management Practice
CABI Certified Asbestos Building Inspector
CCOD City and County of Denver
CCR Code of Colorado Regulation
CDPHE Colorado Department of Public Health and Environment
CFR Code of Federal Regulation
CMU Concrete Masonry Unit
CSWR Colorado Solid Waste Regulations
DDPHE Denver Department of Public Health and Environment
GPS Global Position System
HEPA High-efficiency Particulate Air
HVAC Heating, Venting and Air Conditioning
IDW Investigation-derived Waste
MMP Materials Management Plan
mph Miles Per Hour
Environmental Quality Division Denver Department of Public Health & Environment
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Acronym Definition
NIOSH National Institute for Occupational Safety and Health
NIST National Institute of Standards and Technology
NVLAP National Voluntary Laboratory Accreditation Program
OSHA Occupational Safety and Health Administration
PCM Phase Contrast Microscopy
PLM Polarized Light Microscopy
Poly Polyethylene
PPE Personal Protection Equipment
PSRMP Project-Specific Regulated Asbestos Contaminated Soil Management Plan
RACS Regulated Asbestos Contaminated Soil
RWA Regulated Work Area
TEM Transmission Electron Microscopy
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Definitions
“Adequately wet” means sufficiently wet to minimize visible emissions of dust and/or debris within the
regulated work area (RWA) and to prevent the release of visible emissions from leaving the RWA. The
observance of visible emissions, outside of the RWA, of dust and/or debris may be an indication that
soils are not adequately wet.
“Adjacent Receptor Zone” means an area of uncontrolled access at a distance of 150 feet or less from
the nearest RWA boundary during active Regulated Asbestos Contaminated Soil (RACS) disturbance. For
the purpose of this definition, highways, streets, and roads without sidewalks, where only vehicles are
permitted, are considered to be areas of controlled access and therefore not adjacent receptor zones.
For the purpose of this definition "vehicle" means a device that is capable of moving itself, or of being
moved, from place to place upon wheels, including bicycles and electrical assisted bicycles. For the
purpose of this definition, an area for which access is not ordinarily controlled that is closed to the
public during soil disturbing activities in the adjacent RWA is considered to be an area of controlled
access and therefore not an adjacent receptor zone.
“Amended water” means water containing a wetting agent, such as a 50:50 mixture of polyoxyethylene
ester and polyoxyethylene ether, or the equivalent, in a 0.16 percent solution (1 ounce to 5 gallons) of
water, or as per manufacturer recommendations for the wetting of asbestos.
“Air Monitoring Specialist” (AMS) means a person trained and certified, in accordance with the
requirements of Air Quality Control Commission Regulation No. 8 (5 Code of Colorado Regulation [CCR]
1001-10, Part B) (CDPHE, 2008), for the collection of air samples to determine airborne particulate
and/or asbestos concentrations.
“Asbestos” means the asbestiform varieties of serpentine (chrysotile) and amphibole minerals,
riebeckite (crocidolite), amosite (cummingtonite-grunerite), anthophyllite, actinolite, and tremolite.
"Asbestos-containing material” (ACM) means any material that contains more than one percent (1%)
asbestos by weight, area or volume. It is during a CABI’s RACS/Non-RACS Determination that ACM will
be analyzed for.
“Asbestos Worker” means an individual trained and certified under the Colorado State Regulation No.
8, Part B to disturb, enclose, remove, and abate friable and non-friable asbestos containing material.
“Certified Asbestos Building Inspector” (CABI) means a person trained and certified in accordance with
Air Quality Control Commission Regulation No. 8, (5 CCR 1001-10, Part B), for the identification of
asbestos containing materials and the collection of samples to determine asbestos content inspection
and sampling, and who has forty (40) verifiable hours of on the job asbestos in soils experience on a
minimum of three (3) different asbestos in soils projects, conducted under either AQCC Regulation No. 8
or CSWR §5.5. The CABI shall be independent of the general contractor (GC) and/or abatement
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contractor unless the CABI and the GC or abatement contractor are both direct employees of the
property owner. However, the GC or abatement contractor may hire a subcontractor CABI, but the CABI
shall not be a direct employee of the GC or abatement contractor.
“Consultant” refers to the entity contracted to perform all oversight actions in the form of training,
inspections, field directions, air monitoring and documentation related to soil disturbing activities in
accordance with this standard operating procedure.
“CSWR” refers to the Colorado Solid Waste Regulations (6 CCR 1007-2). The sections most applicable to
this standard operating procedure are Section 5 “Asbestos Waste Management”, and specifically Section
5.5 “Management of Regulated Asbestos Contaminated Soil (RACS)”.
“Debris” means any discarded material that contains or consists of any of the following: construction,
renovation and demolition debris (regardless of how it was generated), building or facility components,
components of building systems (heating, venting, air condition [HVAC], plumbing, electrical, control,
fire protection, roofing), components of pavement or drainage systems, industrial or machinery
components, and/or mechanical components from motorized vehicles.
“Debris Determination” for the purpose of this standard operating procedure, means a determination,
conducted in the field by the contractor and/or their sub-contractors for the possibility of visible debris
to be either Non-Suspect for ACM or Suspect for ACM. Determinations of Non-Suspect/Suspect shall be
based on the requirements set forth in Section 4.1 & 4.2 of this standard operating procedure.
“Facility Component” - for purposes of this standard operating procedure, means any part of a facility including equipment. For the purpose of this definition, “facility” means (as defined in Air Quality Control Commission Regulation No. 8 (5 CCR 1001-10, Part B): “any institutional, commercial, public, industrial, or residential structure, installation, or building (including any structure, installation, or building containing condominiums or individual dwelling units operated as a residential cooperative, but excluding: residential buildings having four or fewer dwelling units); any ship; and any active or inactive waste disposal site. For purposes of the definition, any building, structure, or installation that contains a loft used as a dwelling is not considered a residential structure, installation, or building. Any structure, installation or building that was previously subject to this subpart is not excluded, regardless of its current use or function.”
“Friable ACM” means any material that contains more than one percent asbestos by weight, area, or
volume, and when dry can be crumbled, pulverized, or reduced to powder by hand pressure. The term
includes non-friable forms of asbestos after such previously non-friable material becomes damaged to
the extent that when dry it can be crumbled, pulverized, or reduced to powder by hand pressure as
determined in the field by a CABI.
“General Abatement Contractor” refers to State-certified entity contracted to perform asbestos
contaminated soil disturbing activities in accordance with the standard operating procedure.
“Geofabric” means a permeable fabric or synthetic material used for both visual and physical
separation.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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“Green Waste” biodegradable waste that can be composed of garden or park waste, such as grass or
flower cuttings and hedge trimmings, as well as domestic and commercial food waste.
“Mechanical” means operated or produced by mechanism, tool or machine. This may include but shall
not be limited to, an excavator, backhoe, grader, tiller, auger, or hand shovel.
“Non-regulated Asbestos Contaminated Soil” (Non-RACS) means soil or debris that has been inspected
by a CABI to contain only:
• Intact non-damaged, non-friable ACM(s).
• Damaged non-friable ACM(s) that do not have a high probability to release fibers based on
the forces expected to act upon the material during disturbance as determined in the field
by a CABI(s) through a “RACS Determination”. The following ACM(s) are predetermined to
be Non-RACS:
o Resin-based materials including but not limited to phenolic-plastic (Bakelite), used in
electrical and mechanical parts
o Resilient flooring (vinyl, asphalt, rubber) excluding non-tar impregnated friable felt
backing on sheet vinyl flooring (linoleum)
o Tar-impregnated or asphaltic materials in good condition that have not become
brittle
o Elastic, pliable, or rubberized materials, including but not limited to:
▪ Pliable duct sealant
▪ Pliable fiberglass insulation sealant
▪ Pliable fire-stop caulking /sealants
▪ Pliable window and door caulking
o Extremely hard materials, coatings and sealants including but not limited to:
▪ Laboratory countertops and sinks
▪ Epoxy-type Concrete Masonry Unit (CMU) coatings
▪ Epoxy-type panel adhesive
▪ Duct sealant
▪ Ceiling tile adhesive
o Other ACM(s) as approved by the Department at the request of the owner or person
disturbing debris, to not have a high probability to release fibers.
Environmental Quality Division Denver Department of Public Health & Environment
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“Suspect Debris” means non-soil debris that is Suspect, including ash, to contain ACM. This material
requires a RACS determination by a CABI, and until the CABI determination is complete, will be assumed
to be RACS and managed in accordance with this standard operating procedure. Although this material
may not require special management as ACM, it may still require management as a solid waste. Co-
mingled Suspect and Non-Suspect debris should be managed as Suspect Debris.
“Non-soil Debris” means materials entrained within the soil matrix that are not composed of soil. These
may include Non-RACS, RACS, or Non-Suspect. Often associated with uncontrolled fill, or historical urban
fill areas.
“Project-specific Regulated Asbestos Contaminated Soil Management Plan” (PSRMP) means a RACS
management plan for a single project submitted in accordance with CSWR §5.5
“Regulated Asbestos Contaminated Soil” (RACS) means soil, ash or debris (plus six inches in all
directions of surrounding soil or other matrix material) containing:
• Friable ACM as determined in the field by a CABI through a RACS determination; Previously
non-friable ACM(s) that have been rendered friable as determined in the field by a CABI(s)
through a RACS determination.
• Non-friable ACM(s) that have a high probability of releasing fibers based on the forces
expected to act upon the material during soil disturbance as determined in the field by a
CABI(s) through a RACS determination; deteriorated non-friable ACM(s) that are in poor
condition resulting in a high probability to release fibers due to weathering, historical
mechanical impact, fire damage (by evidence of ACM within an ash layer) or other factors as
determined in the field by a CABI(s) through a RACS determination.
• The following broken, resized, or damaged ACM(s) are predetermined to be RACS:
o Asbestos cement materials
o Plaster
o Brittle caulking, glazing and sealants
o Powdery Concrete Masonry Unit (CMU) sealant
o Powdery floor leveling compound
o Drywall/wallboard and associated joint compound material
o Firebrick
o Other material as determined by the Department, at the request of the owner or
person disturbing debris, to have a high probability to release fibers.
• Soil or ash known to contain non-visible asbestos based on documented evidence.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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“RACS Determination” for the purpose of this standard operating procedure means a determination,
conducted in the field by a Certified Asbestos Building Inspector (CABI), of the friability of Asbestos
Containing Material (ACM) and the probability of non-friable ACM to release fibers based on the
condition of the material and the forces that are expected to act on it during disturbance.
Determinations of friability shall be based on the requirements for such determinations set forth in Air
Quality Control Commission Regulation No. 8 (5 CCR 1001-10, Part B). Determinations of the probability
for non-friable ACM to release fibers during disturbance shall be based on the following:
1) The condition of the material prior to disturbance, based on observations of weathering, the integrity
of the material, historical mechanical impact, or fire damage;
2) The potential for the material to be broken, resized or damaged during planned disturbance;
3) The material shall be considered RACS if the planned disturbance includes any of the following:
a. Augers
b. Rotary style trenchers
c. Driving on ACM lying on the surface (vehicles or equipment)
d. Blasting or other detonation
e. Intentional burning
f. Other types of direct mechanical impact which are:
i. In direct contact with ACM or result in observation of ACM after disturbance, and
ii. Causing damage to the ACM
“Regulated Work Area” (RWA) means the portion(s) of a site at which soil disturbing activities involving
RACS occur
“RACS Disturbance” means activities such as removal, management, or other physical disturbance of
RACS
“Soil-disturbing Activities” means digging, excavating, staging, loading, stockpiling, backfilling,
compacting, grading, tilling, drilling, intrusive sampling, and equipment or vehicle movement or any
other mechanical activity, that when used, disturbs the surface and/or subsurface soil. Disturbance or
removal of soil, or soil with debris and/or RACS is considered a soil-disturbing activity. Hand disturbance
or removal of RACS is subject to the State Regulation and this standard operating procedure but is not
considered to be a mechanical disturbance.
“Staging” means the accumulation of RACS in the RWA for twelve (12) hours or less.
“Stockpiling” means the accumulation of RACS that will exist for more than twelve hours, up to and
including ten calendar days
Environmental Quality Division Denver Department of Public Health & Environment
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“Storage” means the accumulation of RACS greater than ten days but not exceeding six months unless a
longer timeframe is approved by the Department and DDPHE.
“Visible Emissions” means any airborne or liquid emissions, coming from, or having come into contact
with RACS, which are visually detectable without the aid of instruments. Proper disposal of
appropriately filtered decontamination water does not constitute a visible emission.
“Visual Inspection” means observation with sufficient proximity to identify discrete visible materials,
while maintaining the safety of the inspector.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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1. Introduction
The City and County of Denver (CCOD) recognizes the need for construction activities to have a well-
established agreement in place regarding the risks from management of construction projects where
soil may be impacted by asbestos-containing materials (ACMs). While these agreements modify
traditional construction work practices and required personnel, they do remain consistent with the
established Colorado Department of Public Health and Environmental (CDPHE) rules and regulations and
current industry standards for the management of regulated asbestos-contaminated soil (RACS). Today’s
public safety realities are highlighted by the numerous construction projects that encounter RACS, and
the need for CCOD and its construction partners to have established field standards that protect public
health from exposure to asbestos, and help the projects stay on schedule and on budget. This document
has been prepared to be used on CCOD’s projects. Implementation of this standard operating procedure
on other projects not owned or controlled by the CCOD are in no way the responsibility of the CCOD.
The Denver Department of Public Health and Environmental (DDPHE) and CDPHE have worked
cooperatively to develop a solution designed to be followed by any contractor or its sub-contractor
when performing soil-disturbing activities (as defined within this standard operating procedure) during
excavation at CCOD’s construction projects. Initially, the solution establishes standard operating
procedures that are intended to be followed during construction projects where activities have
disturbed and/or identified non-soil debris within the soil matrix. Additional standard operating
procedures are predicated on the type and amount of non-soil debris and coordination with and the
approval by the CCOD project manager.
Soil that is not to be disturbed by planned construction on a project will remain in-place.
Characterization and remediation of soil not directly disturbed by project activities are beyond the scope
of this standard operating procedure, unless specifically directed by DDPHE. If remedial actions are
required, additional planning would be conducted under the direction of DDPHE.
1.1 Purpose
This standard operating procedure has been prepared to ensure compliance with the Colorado Solid
Waste Regulations CCR 1007-2 Part 1, Section 5.5 (Colorado Solid Waste Regulation [CSWR] §5.5;
CDPHE, 2014), and provides the procedures for identification, safe handling, transport, and disposal of
Non-RACS or RACS that may be encountered during soil-disturbing activities. Provisions of CSWR §5.5,
not specifically referenced within this standard operating procedure, must be followed; therefore, any
contractor working on CCOD projects must be familiar with both this document, and CSWR §5.5. In the
event of any disparity between the two, CSWR §5.5 will supersede provisions included within this
document.
Environmental Quality Division Denver Department of Public Health & Environment
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This standard operating procedure has been prepared to minimize potential delays, and to develop
approved standard procedures that the contractor will implement as needed for future soil-disturbing
where Non-RACS and RACS may be encountered. The quick disseminating of critical information to
participating parties is key to the proper identification of debris, management of Non-RACS and RACS,
and protection of public health and environment.
This standard operating procedure has been approved by the CDPHE (Appendix A) and incorporates by
reference CDPHE Regulations Pertaining to Solid Waste Sites and Facilities (6 CCR 1007-2, Part 1), CSWR
§5.5 - Management of Regulated Asbestos Contaminated Soils (CSWR §5.5). The Regulation can be
found at: https://www.colorado.gov/pacific/cdphe/solid-waste-regulations.
1.2 Applicability
The requirements of CSWR §5.5 apply to the owner or operator of any property with RACS at which soil-
disturbing activities are occurring or planned. The owner/operator may choose to follow the procedures
set forth in CSWR §5.5.1(A) and (B) when debris is exposed or disturbed to determine if the debris is
RACS. Soil-disturbing activities involving Non-RACS, where no RACS is present or generated, are not
subject to the requirements of CSWR §5.5, but Non-RACS must be disposed as non-friable asbestos
waste in accordance with the disposal requirements set forth in Section 5.2 of the CSWR, where
applicable.
It is the responsibility of the general contractor (contractor), including the contractor’s subcontractors,
to incorporate this standard operating procedure into a project’s scope for identifying debris or other
environmental hazards and the subsequent management of that material according to this standard
operating procedure and the Materials Management Plan (MMP) (if applicable). Unless otherwise
written, separate from this standard operating procedure, it is the responsibility of the contractor to
employ appropriate personnel capable of meeting the requirements of this standard operating
procedure and CSWR §5.5 during identification and management of all debris and RACS.
Prior to commencing soil-disturbing activities, if there is no visible or documented evidence, such as
construction drawings or analytical reports or environmental investigations, of RACS during a soil-
disturbing action, the contractor does not have a duty under this standard operating procedure or CSWR
§5.5 to sample or otherwise investigate for RACS. However, if RACS or suspect RACS is discovered, the
contractor is obligated to follow this standard operating procedure.
This standard operating procedure may be incorporated within a MMP and/or Health and Safety Plan
for site-specific safe work practices. Should either of those plans or other site-specific environmental
work plans require changes to this standard operating procedure, the contractor shall present a written
draft amendment to be reviewed by the CCOD Project Manager (who will coordinate with DDPHE) prior
to submittal for review and approval by CDPHE.
Environmental Quality Division Denver Department of Public Health & Environment
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1.3 Non-RACS vs. RACS
As described in CSWR §5.5 (and the definitions presented in this standard operating procedure):
• Non-RACS is soil or debris that contains intact, non-damaged ACM, or damaged non-friable
ACM that does not have a high probability to release fibers as determined by a Certified
Asbestos Building Inspector (CABI) (note, additional description provided in the definitions).
• RACS is soil, ash, or debris (plus 6 inches in all directions) containing friable ACM, non-friable
ACM that has been rendered friable, or deteriorated ACM that has a high potential to
release fibers due to weathering or other processes (note, additional description provided in
the definitions).
Essentially, Non-RACS material contains ACM that is unlikely to release asbestos fibers, and RACS is
material that contains ACM that is likely to release asbestos fibers. Although Non-RACS is technically not
subject to the provisions of CSWR §5.5, disposal requirements still apply per CSWR §5.2. Further, the
presence of Non-RACS still requires special attention during management activities, as there is a high
potential that RACS and Non-RACS may be co-located at a project, or that management activities may
result in Non-RACS releasing asbestos fibers, and thus transforming into RACS.
1.4 Project-specific Regulated Asbestos Contaminated Soil
Management Plan
As determined by DDPHE, a Project-specific Regulated Asbestos Contaminated Soil Management Plan
(PSRMP) may be prepared for individual projects; the PSRMP would detail project-specific RACS
management protocols, amended best management practices (BMPs), or other applicable changes to
this standard operating procedure. If DDPHE determines that a PSRMP is necessary, the PSRMP would
be reviewed and approved by DDPHE then CDPHE, and management techniques may supplant those
presented in this standard operating procedure. At a minimum, this standard operating procedure
should be utilized a foundation for the PSRMP.
1.5 Key Parties and Responsibilities
The following table provides contact and general responsibility information for key parties. A full
contacts list may not be established at the beginning of every project. In cases where RACS management
will be needed, contact information shall be amended as required.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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Table 1 Key Parties and Responsibilities
Responsibilities for key personnel are summarized in Table 2, and discussed in detail in the standard
operating procedures. Key personnel will be contacted as required, as described in the text of the
standard operating procedure.
Party Contact Responsibility
CDPHE
Brian LongPhone: 303-691-4033Email: [email protected] Regulatory Agency – State of Colorado
CCOD – DDPHE
Steve Gonzales Phone: 720-865-5447 Email: [email protected]
If no immediate response, call 720-460-1706
Environmental Quality Technical Oversight – City and County of Denver
CCOD Project Manager TBD Overall project management of CCOD Project
Contractor TBD General Construction; RACS Management
Specialized Abatement Contractor (if applicable)
TBD RACS Management
Environmental Consultant (CABI, AMS)
TBD
CABI, RACS Oversight and if necessary Air Monitoring Specialist (AMS); discovery notification to CCOD Project Manager and DDPHE, and to CDPHE if approved by DDPHE
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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Table 2 Responsibilities
Duties per Standard Operation Procedure
Project Personnel
Contractor Sub-
contractors CABI
Air Monitoring Specialist
(AMS) GAC
Provide Awareness Training ☒ Receive annual RACS Awareness Training (All Site Personnel)
☒ ☒ ☒
Receive Project-Specific Annual Asbestos Awareness Training (to enter any Regulated Work Area [RWA] during RACS disturbance)
☒ ☒ ☒ ☒ ☒
Environmental Consultant Responsibilities
☒ ☒
Handling, Disturbing, Removing RACS ☒ ☒ ☒ ☒ ☒ Decontamination of Equipment, Personal Protective Equipment (PPE) and RWA
☒ ☒ ☒
Wind Speed Monitoring ☒ ☒
Air Monitoring ☒
Documentation ☒ ☒ ☒ ☒ ☒
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
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2. Process Flow and Decision Scenarios
The following process flow and corresponding figures present the more likely scenarios related to the
discovery of debris and management of RACS for CCOD’s projects, and the decisions to be made for
conducting continued soil-disturbing activities under these discovered conditions. Note that these
scenarios are general. Each RACS discovery and project is unique, so the actual steps necessary to
reasonably respond to a RACS discovery and management may change. Coordination with DDPHE on the
most practical management strategy is required when there is reason to believe that RACS is present or
is identified.
2.1 Scenarios
This standard operating procedure has been prepared to provide guidance for five soil-disturbing
scenarios, which are described in detail below.
2.1.1 Excavation in Areas with No Debris
This scenario applies when soil disturbance is planned and there are no RACS concerns (e.g., soil that is
“clean” with no visible debris) (Figure 1). This scenario applies where the contractor has been provided
information from the CCOD Project Manager, or has determined for himself, that the project area is not
likely to have RACS or Non-RACS present because, through visible inspection or other research, no
debris is present. The contractor will then proceed with work as planned, but must be familiar with this
standard operating procedure, and must be observant regarding unexpected debris discovery.
2.1.2 Excavation in Areas with Non-Suspect Debris
This scenario applies when soil disturbance would occur in areas where Non-Suspect Debris is present
[e.g., soil containing pieces of clean concrete (with no associated or attached materials)], but when no
Suspect Debris has been identified (Figure 2). In this standard operating procedure, the contractor is
empowered to make this determination himself. However, if the contractor is unsure of the nature of
debris, a CABI should be consulted to provided certainty of the debris identified. Additional information
about the classification of debris is presented in detail in Section 4.
2.1.3 Discovery of Suspect Debris or Suspect RACS During Excavation
This scenario applies when soil disturbance occurs where Suspect Debris, including RACS, is suspected or
encountered unexpectedly (e.g., work within a known historical urban fill area
[https://www.denvergov.org/opendata/dataset/city-and-county-of-denver-historical-fill-areas] (Figure
3). There are many areas in the CCOD where uncontrolled fill is present in the subsurface, including
historical urban fills, areas where buildings once stood but have since been demolished, areas where
Environmental Quality Division Denver Department of Public Health & Environment
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channelization along streams and rivers occurred or where floodplains or gravel pits were filled, or
where heavy industries were once present. A key component of discovery is to: conduct interim actions
that are described in this standard operating procedure in detail; contact a CABI to make a RACS
determination; and, coordinate stabilization, removal actions and required documentation.
2.1.4 Excavation in Areas with Known RACS
This scenario applies where soil disturbance is planned in an area where known RACS is present (as
confirmed through prior investigation or via a RACS determination by a CABI) (Figure 4). In this scenario,
careful planning would be conducted to perform management actions in accordance with this standard
operating procedure and CSWR §5.5.
2.1.5 Subsurface Investigations
This scenario applies when soil disturbance is conducted related to subsurface investigations, including
environmental, geotechnical or utilities (Figure 5). These investigations are generally small in scale,
where a drill rig may be used to drill a small-diameter hole to evaluate geologic conditions; a small test
pit/trench is excavated to visually assess subsurface conditions (primarily in the investigation of Suspect
Debris conditions); or a vacuum truck/water knife is used to locate a utility line. Detailed analysis of the
RACS management strategies are presented in Section 5.1.5 of this standard operating procedure. Note,
if a utility investigation utilizing a vacuum truck/water knife is proposed in a known historical urban
fill site and/or area with known RACS or Suspect Debris, additional project-specific planning will be
necessary BEFORE work is initiated as there is a high potential that equipment may become
contaminated. Coordination with DDPHE will be required.
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Figure 1 Excavation in Areas with No Debris
There is no reason to
believe Non-Suspect,
Suspect Debris or RACS is
present in soil
Contractor shall read
and understand this
standard operating
procedure
Yes
No
Soil-disturbing activity
commences;
contractor visually
observant about
possible debris
Excavation continues;
contractor remains
observant about
possible debris
Proceed to Figure 2 –
Non-Suspect Debris
Suspect Debris and/or RACS (Section
2.1.3 and 4.2)?
Non-Suspect Debris
(Section 2.1.2 and 4.1)?
Conduct interim actions
(Section 5)
Proceed to Figure 3 –
Discovery of Suspect
Debris
Yes
Or
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Figure 2 Excavation in Areas with Non-Suspect Debris
Non-Suspect Debris
identified during soil-
disturbing activities or in
pre-project planning
Contractor shall read
and understand this
standard operating
procedure
Excavation commences;
contractor observant about
possible Suspect Debris
Manage material in
accordance with MMP
(if applicable) and City
Soil Reuse Policy
(Section 3.6)
Conduct interim actions
(Section 5)
Proceed to Figure 3 –
Discovery of Suspect
Debris or Suspect
RACS
Yes
Debris is confirmed to
be Non-Suspect as
defined in this standard
operating procedure
Suspect Debris
identified?
Yes
Or
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Figure 3 Discovery of Suspect Debris or Suspect RACS During Excavation
During project planning and
design, or during
construction, Suspect
Debris, is present or may be
discovered.
Contractor shall read
and understand this
standard operating
procedure and training
requirements
May include Non-RACS
materials. Manage material
in accordance with MMP (if
applicable) and/or City Soil
Reuse Policy (Section 3.6).
Soil-disturbing activities done
in areas with construction
debris must be conducted in
presence of CABI until no
suspect materials or
construction debris remain.
Conduct interim actions
(Section 5);
CABI to evaluate
presence of asbestos
and make a RACS
determination
Proceed to Figure 4 –
Known RACS
Suspect
Debris
identified?
No
If Suspect Debris is
visually detected,
excavation in soil shall
be conducted only in
the presence of CABI
RACS
Confirmed?
Yes
Yes
No
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Figure 4 Excavation in Areas with Known RACS
During project planning
and design, or during
construction, the presence
of RACS is confirmed
Contractor shall read
and understand this
standard operating
procedure and
training requirements
Hand removal of RACS.
Complete work in accordance
with Section 7.1 of this
standard operating procedure.
Determine, in
coordination with
DDPHE, if hand
removal or
mechanical removal
techniques will apply
No
All soil disturbing
work shall be
conducted in
accordance with this
standard operating
procedure
Hand Removal Selected
Mechanical removal of RACS.
Complete work in accordance
with Section 7.2 of this
standard operating procedure.
Mechanical Removal Selected
RACS
Removed?
Excavation continues; contractor
remains observant about possible
debris and conducts visual debris
determination. Manage material in
accordance with MMP (if applicable,
where solid waste, Non-RACS, or
other special waste materials are
present, and in accordance with City
Soil Reuse Policy [Section 3.6]).
Yes
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Figure 5 Subsurface Investigations
During project planning and design, CCOD intends to conduct
subsurface investigation to evaluate subsurface geotechnical
and/or environmental, and/or utility conditions
Contractor shall read and
understand this standard
operating procedure
Conduct investigation with
oversight of CABI; verify
investigation methodology with
DDPHE
Yes No
Reason to believe
that Suspect
Debris may be
present?
Investigation commences;
contractor observant about
possible Suspect Debris
Suspect Debris
identified?
No
Stop work. CABI conducts
sampling. Note, if
conducting utility
investigation with vacuum
truck/water knife, stop
work and consult DDPHE.
Immediately replace Suspect
Debris at bottom of boring,
test trench, test pit; cover
with clean at least 18 inches
of Non-Suspect over-burden
soil
If additional investigation is
to be performed at project
location, CABI must be
present
Report results to DDPHE, including
location, depth, disposition of
material. Utilize findings to determine
applicable action for project design
and construction
Yes
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3. General Requirements
The following sections describe general requirements for the management of RACS.
3.1 Training for Site Personnel
As described in CSWR §5.5.3, personnel overseeing, directing, inspecting, and/or handling RACS
(including suspect asbestos) and all personnel inside the Regulated Work Area (RWA) during the
disturbance of RACS, shall have annual asbestos awareness training, and provide documentation to the
CABI.
Personnel who enter the RWA during disturbance of RACS will receive project-specific training by a CABI
familiar with this standard operating procedure and CSWR §5.5, as well as the project. This includes
drivers of trucks carrying contaminated material for off-site disposal. The training will cover the
provisions of this standard operating procedure, as well as the following:
• Background of asbestos, including health effects
• Overview of the requirements of CSWR §5.5 and this standard operating procedure and its
implementation
• Recognition of Suspect Debris that may contain asbestos and which requires further
evaluation by a CABI
• Overview of Non-Suspect Debris, Suspect Debris, RACS, and Non-RACS, and standard
operating procedure protocols for each
• Controls and notifications to be followed when debris that may contain asbestos is
encountered
• The nature of operations that could result in exposure to asbestos fibers
• Spill prevention and contamination reduction techniques
• Proper use, handling, and disposal of PPE
• Respiratory protection levels required for various activities and conditions
• Engineering controls and other measures to prevent contact with contaminants
• Engineering controls to prevent visible emissions from leaving the RWA
• Personnel and equipment decontamination and the establishment of decontamination
stations
• Emergency procedures
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• Project chain-of command and identification of authorized personnel with stop-work
authority
• Hands-on training specific to the soil-disturbing activities the individual will be performing
subject to CSWR §5.5.
Records of this training will be retained by the CABI, and will be available for inspection for the duration
of the project for which the training is conducted.
3.2 Health and Safety
There is a potential for increased risk to the health of workers during disturbance/removal of RACS.
Awareness by site personnel of these hazards is of the highest priority. Therefore, a site-specific Health
and Safety Plan will be developed by the contractor prior to any RACS management. Site personnel will
be provided with a copy of the Health and Safety Plan for review, and will be required to sign a form
stating that they are aware of, agree to, and understand the requirements of the plan. The contractor
will be required to employ the proper personnel, and PPE, to provide a safe working environment for its
employees, consultants and subcontractors.
3.3 CABI and AMS Requirements
When a Discovery of Unknown Suspect Debris or Suspect RACS, or Known RACS is present, a CABI who
meets the training, certification, and experience requirements of CSWR § 5.5.3(D) (and an Air
Monitoring Specialist [AMS] if a RWA is required) shall be on-site on a full-time basis during all soil-
disturbing activities, to physically observe and monitor the air and site conditions and provide
information to the contractor to help limit and avoid asbestos fiber release. The CABI and AMS can be
the same person if she/he meets the CABI and AMS requirements listed below. Ideally, the CABI and
AMS will be the same person. Depending on site conditions and scope, more than one CABI, AMS, or
both may be required.
When a Discovery of Suspect Debris or Suspect RACS, or Known RACS, is present, the CABI(s) will be
responsible for the following:
• Have all current applicable training certificates and State of Colorado Certification(s) in
accordance with the CDPHE-Air Quality Control Commission (AQCD Reg. 8) and Hazardous
Materials and Waste Management (HMWMD) regulations to be a CABI (CSWR § 5.5.3 (D)).
• Be on-site on a full-time basis and continuously observe all soil disturbing, excavation, and
loading activities.
• Identify if suspect RACS is present.
• Complete necessary sampling of suspect asbestos, and make RACS determination(s).
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• Complete CABI Work Day Documentation Form (Appendix B), thoroughly detailing site
activities as presented in Section 8 – Close Out Report.
• Maintain all pertinent documentation related to adherence of the standard operating
procedure, including sampling results, air monitoring data, waste manifests, photographs,
etc.
• Inspect the RWA and equipment after removal of RACS to evaluate whether remaining ACM
is present on the surface or on equipment.
• The CABI will have “Stop Work” authority if it is believed that work is being performed
outside the guidelines of this standard operating procedure or of CSWR §5.5, or if actions
harmful to life and health, or the environment, are observed; the CABI will not be
responsible for consequential damages for any work stoppage, including real or perceived
harm, including lost productivity, that may result.
• Notification of RACS disturbance to CDPHE on behalf of the contractor.
• Updates to CCOD Project Manager and CDPHE on contractor decisions regarding RACS
management.
• Notification of deviations from this standard operating procedure to the CDPHE (note:
deviations from this standard operating procedure and/or CSWR §5.5 will require approval
by DDPHE and CDPHE; deviations may be addressed through preparation of an amendment
to this standard operating procedure, PSRMP, or other means as approved).
• Monitor and log wind speed and direction during soil disturbing activities.
If RACS management is required by Section 7.2.5 of this standard operating procedure or CSWR §5.5,
the AMS(s) will be responsible for the following:
• Have all current applicable training certificates and State of Colorado Certifications in
accordance with the CDPHE-AQCD regulations to be an AMS (Air Quality Control
Commission Regulation No. 8 (5 CCR 1001-10, Part B).
• Be on site on a full-time basis during disturbance, excavation, and loading of RACS.
• Monitor RWA during removal and disposal of RACS for compliance of this plan.
• Place and monitor air samples on site and around RWA during soil-disturbing activities.
• Monitor and log wind speed and direction during soil disturbing activities.
• The AMS will have “Stop Work” authority if it is believed that work is being performed
outside the guidelines of this plan or of CSWR §5.5, or if actions harmful to life and health,
or the environment, are observed; the AMS will not be responsible for consequential
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damages for any work stoppage, including real or perceived harm, including lost
productivity, that may result.
• Submitting an Emission Control Plan for each detection of asbestos by TEM analysis as
required by CDPHE in accordance with CSWR § 5.5.7 (E)(2)(f)(i)(ii) & (iii).
3.4 Contractor Requirements
The following contains requirements for the contractor performing RACS disturbance/removal:
• The contractor shall provide documentation to the CABI and CCOD that all individuals
performing RACS-disturbing activities have completed a project-specific awareness training
that provides information necessary to perform their duties in a way that ensures
compliance with the requirements of the CSWR §5.5. If the contractor cannot provide this
documentation, then the applicable training will be conducted by the CABI.
• The contractor shall ensure that individuals performing RACS-disturbing activities have
completed asbestos awareness training in accordance with Occupation, Safety and Health
Administration (OSHA) 29 Code of Federal Regulations (CFR) 1926.1101(k) Communication
of Hazards - (9)(10) .
• Records that document the training, experience, or certification requirements in CSWR §5.5.
Documents shall be available on-site for review throughout the duration of soil-disturbing
activities.
• The contractor will be required to prepare and implement a Health and Safety Plan in
accordance with the applicable regulations, including OSHA. The contractor will be
responsible for the health and safety of its employees, subcontractors, consultants, etc., as
well as provide all necessary training and PPE for completion of work.
• The contractor will be responsible for maintaining all necessary site controls to prevent
unauthorized entry into the RWA in accordance with Section 5.2 of this standard operating
procedure, and with CSWR § 5.5.7(A) “Establishment and Control of a Regulated Work Area
(RWA)”.
• The contractor will be responsible for adherence to this plan at the direction of the
CABI/AMS. The CABI/AMS will be completing air monitoring in accordance with Section
7.2.5. Based on the air monitoring results, the CABI/AMS will direct the contractor to
institute additional BMPs, if necessary, to eliminate fugitive dust emissions or visible
emissions.
The following contains requirements for the contractor performing any soil disturbing activity:
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3.5 Notifications
The Notification of RACS Disturbance form (Appendix C) must be submitted to CDPHE prior to
commencing work in planned RACS management or within twenty-four (24) hours of unexpected
discovery of RACS areas. The notification shall indicate which management approach will be utilized per
the project’s soil-disturbing scenario as presented in Section 2 of this standard operating procedure:
• Use this standard operating procedure (and note what, if any, deviations are proposed [with
DDPHE approval]); or
• A project-specific PSRMP (with DDPHE approval); or
• Standard Requirements of CSWR §5.5 (with DDPHE approval).
Planned RACS disturbance shall not commence until approval has been granted by CDPHE. Notification
must have the approval of the CCOD Project Manager and DDPHE must be notified before any
notification is submitted to CDPHE. Notification is not required when only sampling debris for ACM
content by a CABI.
For all soil-disturbing activities where the contractor or subcontractor will perform RACS management:
• Within twenty-four (24) hours of unplanned RACS discovery, the contractor or CABI shall
submit a Notification of RACS Disturbance form (Appendix C) to CDPHE indicting that the
project will be using the RACS management steps as detailed in this standard operating
procedure.
• Ten (10) days prior to start of RACS disturbance for planned RACS management, the
contractor or CABI, shall submit a Notification of RACS Disturbance form (Appendix C) to
CDPHE indicting that the project will be using the RACS management steps as detailed in this
standard operating procedure.
• Notification of RACS Disturbance form shall be emailed to CDPHE address on the form, and
copied to the CCOD Project Manager and DDPHE contact.
• Maps, figures, drawings, or other applicable information shall be included with the
Notification of RACS Disturbance form.
• In the event of an emergency (a condition which is immediately dangerous to life or
property; e.g., broken water main, broken gas line) in which a soil-disturbing activity must
continue or commence at once, notification shall be made as soon as possible, but within 24
hours of identifying or assuming the presence of RACS within the soil-disturbing area. During
the initial response to the immediate emergency, the standard requirements of RACS
management in accordance this standard operating procedure shall be implemented to the
extent possible. Within 48 hours, any disturbed and/or exposed RACS shall be managed in
accordance with this standard operating procedure.
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• RACS management must be approved by the CCOD Project Manager prior to commencing
ongoing soil-disturbing activities involving RACS. Exceptions would be RACS inspection,
stabilization, and necessary decontamination activities. Any planned changes to this
standard operating procedure must be approved by the CCOD Project Manager, DDPHE, and
CDPHE prior to commencing RACS disturbance activity.
3.6 Soil Reuse
In some circumstances, an MMP will be prepared for a project. Soil reuse, and management of soil not
impacted by RACS, should be followed in accordance with the MMP. If an MMP is not available,
coordination with DDPHE, and potentially CDPHE, may be necessary. Regardless, all CCOD projects
must follow the DDPHE Guidance for Reuse of Soil on City Projects. Some general requirements (but not
all requirements) are described as follows:
• If the soil generated at a project would be reused at a third-party property, coordination
with DDPHE will be required, as well as other requirements noted in the Guidance for Reuse
of Soil on City Project, which define soil quality and analytical requirements.
• Soil that is proposed for reuse at a CCOD-owned park must meet the requirements defined
for Unrestricted Reuse, and cannot contain any debris (Suspect or Non-Suspect).
• Soil that is not to be disturbed by planned construction on the project will remain in-place,
regardless of its reuse classification. Characterization and remediation of soil not directly
disturbed by project activities are beyond the scope of this standard operating procedure,
unless specifically directed by DDPHE. If remedial actions are required, additional planning
would be conducted under the direction of DDPHE.
• No debris (including Non-Suspect), RACS, or impacted soil may be left exposed at final grade
surfaces. Depending on the conditions discovered, it may be necessary to over-excavate
these materials 12 inches or more (18 inches minimum if RACS is present), and backfill with
clean soil to the final grade (see Section 5.1 of this standard operating procedure).
• No soil containing debris, whether Suspect or Non-Suspect, may be reused onsite or off-
site. There may be certain circumstance where approval may be obtained, but only through
coordination with DDPHE, and possibly with CDPHE, in accordance with applicable
regulations.
• All soil destined for landfill disposal, including RACS managed according to this standard
operating procedure, must be disposed under proper waste characterization and waste
profiling procedures at the Denver-Arapahoe Disposal Site.
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4. Debris Identification
The contractor and/or sub-contractor(s) to the contractor, while performing soil-disturbing activities
under this standard operating procedure, shall have the responsibility of inspecting all soil-disturbing
activities through continuous visual inspection for the presence of Suspect Debris or Non-Suspect
Debris. All visible debris will have a debris determination as non-suspect for ACM (Non-Suspect), or
suspect for ACM (Suspect). The contractor/sub-contractor shall follow the directions given in this
standard operating procedure related to findings and debris classifications. If the contractor/sub-
contractor is unsure of a classification or unable to make this classification, the contractor/sub-
contractor shall contact a CABI to assist in the final classification of soil and/or debris, or contact DDPHE.
The contractor and/or sub-contractor shall evaluate any debris encountered to see if it meets the
parameters of Section 4.1 of this SOP and CSWR § 5.5.2 (H) & (I) during all soil-disturbing activities. To
ensure an accurate evaluation is made, any contractor and/or sub-contractor performing any soil-
disturbing activities while operating under the provisions of this SOP and not identified as a General
Abatement Contractor, shall be required to have all project field personnel complete a general RACS
awareness training as detailed in CSWR § 5.5.3 (A) annually. This training is required to be presented by a CABI that meets the training and experience requirements of section CSWR § 5.5.3 (D) and will specifically address all necessary protocols and actions for debris identification regarding sections 4.1
and 4.2 of this SOP. Furthermore, the contractor and/or sub-contractor shall document their debris
evaluation(s) and debris encounters(s). Debris documentation and training records shall be made
available at upon request by CCOD and/or CDPHE.
4.1 Debris Classified as Non-Suspect for ACM
Materials will be defined as non-suspect for ACM when it meets the following criteria:
• The material is soil only, where there are no visible signs of construction debris at the point
of soil disturbance; or
• Soil that contains the following non-suspect debris:
o Metal - with NO associated materials on it (e.g. sealants, insulation, adhesives, etc.)
o Glass - with NO associated materials on it (e.g. caulking, glazing, sealants, etc.)
o Plastic - with NO associated materials on it (e.g. sealants, adhesives, etc.)
o Wood - with NO associated materials on it (eg. drywall, plaster, adhesives, caulking, etc.)
o Concrete - bare, with NO associated materials on it (e.g sealants, adhesives,
waterproofing, tars, floor tiles, etc.)
o Plant material, including plant wastes from the food processing industry and vegetative
food waste
o Yard trimmings
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o Untreated wood wastes
o Non-industrial and non-insulative paper products (e.g., newspaper, magazines, food
wrappers)
o Debris that has been evaluated during a project-specific subsurface investigation, and
has been determined by a CABI as Non-Suspect (documentation must be maintained on
the project at all times); special caution is recommended, as subsurface conditions in
areas where filling has been conducted can be highly variable, and unexpected
discoveries may be identified
o Or other material as approved by CDPHE
4.2 Debris Classified as Suspect for ACM
The contractor shall classify all other debris types not specifically listed as non-suspect for ACM above,
as suspect for ACM, and therefore must have a RACS determination completed by a CABI following the
definitions sections of this standard operating procedure and CSWR §5.5, or be assumed to be RACS and
managed in accordance with this standard operating procedure (with approval from DDPHE).
Soil or ash known to contain non-visible asbestos fibers, based on documented evidence such as
construction drawings or analytical reports, is RACS, and if exposed during a soil-disturbing action, shall
be managed in accordance with this standard operating procedure.
Because ash can contain burnt building debris that contains asbestos materials, it is automatically
assumed to be RACS. However, it can be evaluated by a CABI (including through laboratory analysis), to
be non-ACM during the RACS determination.
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5. Initial Actions and Stabilization for RACS Discovery
This section describes the immediate and interim actions that will be implemented by the contractor if
he identifies debris that is classified as suspect for ACM. When Suspect Debris is discovered during soil-
disturbing activities, the critical requirements are: 1) avoid generating dust and avoid being in direct
contact with airborne soil emissions, thereby limiting potential exposure to asbestos fibers; and 2)
stabilize the discovery. Each Suspect Debris encounter scenario will vary; however, the following
general processes must be followed:
• Stop all soil-disturbing activities around the discovery until a CABI’s RACS determination can
be made that has been reviewed by DDPHE.
• Remove all contractor personnel out of the Suspected Debris area.
• Contact DDPHE, and CCOD Project Manager, of the discovery to coordinate next steps.
• A layer of 6-millimeter (mil) polyethylene (poly) sheeting may be used to prevent cross-
contamination onto clean soils during initial characterization activities by placing the poly on
the ground and then placing the potentially contaminated soil, which has been adequately
wetted, directly on the poly.
• Poly will be used to cover the suspect materials to prevent cross-contamination and
spreading; care should be taken to make sure the poly will remain attached to the ground,
even in high-wind conditions.
• Wet the area immediately surrounding the suspect RACS with water, prior to performing
sampling activities that disturb the material (note: visual inspection does not require
wetting). Maintain wet conditions throughout sampling activities.
• Isolate the area where the discovery has been made to prevent worker or public exposure
and cross-contamination. It may be necessary install fencing or other measures to preclude
such access.
• Coordinate with CABI to perform a RACS determination within 24 hours.
• The CABI will evaluate if personnel decontamination is required and advise accordingly.
• The CABI should evaluate equipment for the need for decontamination, and advise
accordingly.
• The CABI will collect samples of the suspect RACS according to procedures provided in this
standard operating procedure (Section 6).
• If leaving the site unattended, cover the disturbed soil with a layer of 6-mil poly sheeting, or
spray with magnesium chloride solution (or equivalent) in sufficient amounts to adequately
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wet the soil to prevent dust generation. The contractor shall implement control mechanisms
to prevent unauthorized or unintended contact with the material (e.g., install fencing).
• After confirmation of RACS by the CABI, the CABI, in coordination with DDPHE, will direct
the contractor on proper implementation of this standard operating procedure.
5.1 Temporary Stabilization Procedures
Any contractor who exposes RACS during a soil-disturbing activity, but does not disturb or come into
contact with the RACS debris, such as a side-wall or bottom of excavation, and determines to have the
RACS remain in place, shall have it covered or stabilized using one of the following methods:
5.1.1 Horizontal Excavation Faces (Excavation Floors)
• Cover RACS with geofabric, followed by eighteen (18) inches of fill suitable for unrestricted
use, and vegetation; or
• Cover RACS with geofabric, followed by six (6) inches of fill suitable for unrestricted use, and
concrete or asphalt.
5.1.2 Vertical Excavation Faces (Excavation Side Walls or Trenches)
• Cover RACS with geofabric, followed by fill suitable for unrestricted use to grade or six (6)
inches, whichever is greater; or
• Alternate cover designs as approved by the CCOD Project Manager and CDPHE.
5.1.3 Standard Requirements for Temporary Sub-Surface Stabilization of RACS.
Any contractor who excavates RACS during a soil-disturbing activity, where it is decided that RACS will
be put back into place for a future planned RACS removal not to exceed six (6) months, shall comply
with the following
• RACS may only be placed within the Area of Contamination (AOC) that it was originally
removed from; and
• Placement and stabilization of RACS shall utilize standard RACS management requirements
in accordance with Section 5.1.1 of this standard operating procedure; and
• Provide DDPHE with a plan to coordinate with the CDPHE on how DDPHE/CCOD will track
the 6-month time storage of RACS.
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5.1.4 Standard Requirements for Permanent Stabilization of RACS
Except as provided in Section 5.5.1(D)(5) of CSWR §5.5, a contractor who disturbs or exposes RACS shall
make the decision upon the initial discovery of RACS to either manage the RACS in accordance with
Section 7 of this standard operating procedure, or cease soil-disturbing activities and permanently
stabilize the disturbed or exposed RACS to control the release of asbestos fibers in accordance with one
of the following:
• Cover RACS with geofabric, or equivalent visible and physical barrier, and restore the site to
pre-disturbance conditions using fill suitable for unrestricted use; or
• Cover RACS with geofabric, or other equivalent visible and physical barrier, followed by
eighteen (18) inches of fill suitable for unrestricted use, and vegetation; or
• Cover RACS with geofabric, or other equivalent visible and physical barrier, followed by six
(6) inches of fill suitable for unrestricted use, and concrete or asphalt; or
• Cover RACS with geofabric, or other equivalent visible and physical barrier, followed by fill
suitable for unrestricted use to grade for vertical excavation faces or trenches; or
• Alternate cover designs as approved by CDPHE.
• Determinations as to what materials would constitute an equivalent visible and physical
barrier replacing geofabric shall be made through consultation with DDPHE and CDPHE.
All procedures shall follow standard requirements for RACS management as per Section 7 of this
standard operating procedure.
5.1.5 Standard Requirements to Stabilize Investigation-Derived Waste
During the process of investigating or examining subsurface conditions during project design, Suspect
Debris (debris classified as suspect for ACM) may be found. Investigations may include: geotechnical or
environmental investigations (generally using continuous-flight augers advanced by a truck-mounted
drill rig); environmental investigations utilizing excavated test pits or test trenches, utilizing an excavator
or backhoe; or utility investigations using a water knife and vacuum truck to locate buried utilities. After
investigation or examination, the soil generated during the investigation may be placed back into the
subsurface area of origination (e.g., soil boring or test pit from which the material came). The following
provisions shall apply:
• Subsurface Suspect Debris locations will be documented and can be made available to
CDPHE upon request.
• Only soil generated during the subsurface investigation, at the location of origination, may
be placed back into the subsurface.
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• Upon discovery of Suspect Debris, drilling or excavation activities will cease. If a CABI is
present, the material will be sampled, and the remaining Suspect Debris will then be placed
directly back into the point of origination, at the deepest depth as practicable.
• Suspect Debris shall be placed at the bottom of the excavation (boring or test pit), and then
covered with clean over-burden soil. At least 12 inches of clean soil must cover Suspect
Debris. If a CABI is not present when suspect material is first identified, investigation and
replacement of soil may not continue until a CABI is present for the remainder of
investigation.
• In lieu of stabilization, Suspect Debris and the surrounding 12 inches of soil can be removed,
and then managed and disposed as RACS in accordance with this standard operating
procedure.
• If a utility investigation utilizing a vacuum truck/water knife is proposed in a known
historical urban fill site and/or area with known RACS or Suspect Debris, additional
project-specific planning will be necessary BEFORE work is initiated as there is a high
potential that equipment may become contaminated. Coordination with DDPHE will be
required.
• The contractor completing the investigation work must report to DDPHE Suspect Debris
discoveries, including the location, depth, and disposition of the material. These findings will
be used to determine applicable actions during the implementation/construction of the
project.
• No additional stabilization or management of Suspect Debris, including RACS if confirmed, is
required after these steps have been completed.
• The CABI will evaluate the need to decontaminate personnel and/or equipment, and advise
accordingly.
• Information collected during the investigation shall be made available to the CCOD Project
Manager and DDPHE, who will consider design strategies during the project design to avoid,
minimize, or mitigate (via this standard operating procedure) RACS during project
construction.
• Notification to the CDPHE of an unexpected discovery is required if stabilization procedures
and documentation to DDPHE are performed in accordance with this standard operating
procedure.
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5.2 Site Access Control
The contractor will be responsible for maintaining effective project access control by establishing and
taking measures to prevent access to the RWA (or areas where discoveries have been made and are
being evaluated) by unauthorized persons. A fence should be erected around the perimeter of the
project area to limit access to the site. Instances of unauthorized access not under the control of the
contractor shall be evaluated to determine if additional access controls are warranted. The unauthorized
access, and the response actions taken, shall be documented and provided to the CDPHE within 48
hours of the incident. Access will be limited to individuals that are approved to be on site.
If RACS is encountered/confirmed, the contactor will install proper signage stating the area is a RWA
because of the presence of asbestos, and that the area is off-limits to unauthorized personnel.
Personnel working on the site shall be advised and directed not to disturb areas where suspected or
known asbestos is encountered. Personnel driving onto the site shall be notified of suspect or known
asbestos locations and directed to not drive on or disturb those areas. At no time will vehicle traffic be
allowed on surfaces where samples have shown positive test results, or where visible asbestos is
present, or where untested suspect materials are located. This excludes equipment that is to remain off
the road and on the project area for removal operations. Project equipment/vehicles moving across
contaminated soils must do so in a way as to not generate visible emissions, and the soil shall be wetted
to control visible emissions. Equipment/vehicles that come into contact with RACS will require
decontamination as per section 7.2.7 of this standard operating procedure.
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6. Suspect Asbestos Bulk Sampling
If Suspect Debris (which is suspect for ACM) is visually identified, the following steps will be applied to
sample and analyze potential ACM by the CABI (only a CABI who meets the requirements discussed in
Section 3.3 of this standard operating procedure may collect samples to determine asbestos content).
Additional information is presented in Appendix D (CSWR §5.5 – Appendix 5A). All sampling and
analysis shall be conducted in accordance with CSWR §5.5 – Appendix 5A.
• Samples of suspect asbestos material will be placed in appropriate sample containers such
as sample bags or jars.
• Care should be taken to ensure that suspect asbestos material is adequately wetted to
prevent visible emissions during the sampling process.
• Bulk samples shall be collected by homogenous type based on color, pattern, texture,
thickness, associated materials, or by other identifying characteristics.
• The quantity and location of a suspect material shall be used to determine the number of
bulk samples required to characterize the asbestos content of each homogeneous suspect
material. For the purpose of determining that a homogeneous suspect material does not
contain asbestos:
o A minimum of three bulk samples shall be collected from the homogeneous material,
unless there is insufficient material to constitute three samples.
o If one of the collected samples of a homogeneous bulk material is determined to be
ACM, then the homogeneous material shall be considered ACM.
• A field sampling form or log book entry will be maintained for each sample obtained. The
form or log book entry will include the location using a hand-held global positioning system
(GPS) instrument, date and time of each sample, depth below the ground surface the
sample was identified, description of the type of material, assessment of friability of the
material, and other observations made.
• Proper chain-of-custody procedures will be followed for all samples collected.
• Samples of newly discovered suspect asbestos materials will be analyzed by a National
Voluntary Laboratory Accreditation Program (NVLAP)-accredited laboratory by Polarized
Light Microscopy (PLM) methodology to determine if any asbestos fibers are present.
• Suspect materials not sampled according to these procedures must be assumed to be ACM
and managed as such.
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7. RACS Management
Through coordination with the CCOD Project Manager and DDPHE, the contractor may be retained to
conduct RACS management. CCOD will require that the contractor, in coordination with the CABI/AMS,
utilize management strategies that are protective of human health and the environment, meet the
CSWR §5.5 requirements, and provide the best value to the CCOD. A detailed scope of work detailing
how this standard operating procedure will be implemented, including costs, will be required prior to
initiating RACS management.
A specialized asbestos abatement contractor may also be retained to conduct these services. Any entity
who wishes to engage in RACS management must understand the intricacies of the CSWR §5.5
regulation, the materials, the risks, and management of the material. Due to the complexity of the work,
it is highly encouraged that only experienced contractors conduct RACS management activities. The
CCOD Project Manager and DDPHE will evaluate the experience and qualifications of the contractor
conducting RACS management prior to implementing RACS management on a project through review of
the detailed scope of work and other qualifications, as requested.
Two standard RACS management strategies are provided in this standard operating procedure, which
are described in this following text. The Hand Removal strategy may be effective where small amounts
of RACS (or Non-RACS) is likely to be found. The mechanical removal strategy may be effective where
large amounts of RACS (or Non-RACS) is likely to be found. Again, the CCOD Project Manager, DDPHE,
and the key parties should thoroughly evaluate site conditions before determining the appropriate RACS
management strategy. Some projects may use both strategies at different times as the most effective
way to manage RACS.
7.1 Hand Removal
During this action, the CABI will direct the contractor (or perform themselves) in the removal of these
pieces of suspect or confirmed ACM (including RACS and Non-RACS) using the procedures listed below:
• The CABI will conduct a visual inspection of area and surrounding surface for the presence
of suspect or confirmed RACS.
• Establish the RWA according to Section 7.2.1 (an RWA is not required if the material is
determined to be a Non-RACS).
• Adequately wet the suspect or confirmed RACS and surrounding soil (12 inches) with
amended water containing a wetting agent, such as a 50:50 mixture of polyoxyethylene
ester and polyoxyethylene ether.
• Gather the RACS and remaining 12 inches of surrounding soil and place into double-bagged,
6-mil poly bags.
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• The CABI will then complete a second visual inspection of the area and surrounding surface
where minimal material was discovered to safeguard that no further RACS is in the scope
area.
• If the CABI encounters further material after removal of the original discovery in which hand
removal is not practical or effective, mechanical removal methods inside a RWA should be
implemented.
• If RACS remains as part of the scope, it shall be managed according with Section 5.1.4 of this
standard operating procedure.
• Dispose of waste in marked, 6-mil poly bags with attached generator labels in accordance
with the CSWR §5.
• Hand-removed, bagged RACS waste may be stored in a leak-tight and secure container
labeled for asbestos, and disposed in accordance with CSWR §5. Bagged RACS may not be
stored for more than 10 days without a CDPHE-approved RACS storage plan.
• Asbestos worker and equipment decontamination shall be performed in accordance with
Section 7.2.7.
Where there are minimal amounts of RACS/Non-RACS discovered as described above, the CABI may
conduct the removal actions as stated in this standard operating procedure, and the utilization of an
abatement contractor is not required (although an abatement contractor may provide trained asbestos
workers to complete removal actions under the supervision of the CABI).
This method may also be applicable where other contaminants are present in soil (such as heavy metals
or petroleum hydrocarbons), which are being managed in accordance with a MMP. During mechanical
removal actions of special solid waste, the CABI must carefully (and safely) observe soil during the
excavation process, prior to the material being loaded into trucks, to ensure that RACS is not
overlooked. It may be necessary for the contractor to remove soil, carefully spread on the ground where
it may be adequately visually inspected by the CABI (wetting as needed so there is no visible dust), and
then re-excavate the material and place in dump trucks for landfill disposal. In no event may excavated
soil that contains non-soil debris of any kind (Suspect or Non-Suspect) (e.g., non-ACM bricks, concrete,
ceramic) be reused at an off-site location, whether if the property is owned by CCOD or not. These soils
must be disposed at the Denver-Arapahoe Disposal Site (3500 South Gun Club Road, Aurora, Colorado
80018) as a special solid waste according with the MMP and CCOD’s soil reuse policy (Section 3.6).
7.2 Mechanical Removal
Mechanical removal of RACS is often the safest and most cost-effective method of RACS management,
particularly where large quantities of RACS/ACM is present, or is expected to be present.
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7.2.1 Establishing a RWA after Confirmed Discovery of RACS
The contractor, under the direction of the CABI, will be responsible for establishing any RWA(s) for
discovered RACS the CABI identifies, which will be removed, as follows:
• Establish a visible perimeter around the discovered material, which is identifiable to all
persons on site, to prevent cross contamination. Demarcate area suspected of containing
RACS with barrier tape, or other means, and provide access control.
• Post-labeling and signage to demarcate RWA(s). The RWA shall be demarcated with a visual
means that defines the full extent of the RWA. Labeling and signage shall indicate the
potential presence of asbestos, and that the area is off limits to unauthorized personnel.
7.2.2 Engineering Controls
7.2.2.1 Initial Minimum Controls
Minimum engineering controls will be implemented when excavations occur within the footprint of the
RWA. The minimum engineering control include, but are not limited to, the following:
• A CABI must observe each area where soil disturbing or loading activities are taking place;
therefore, if multiple excavations are occurring simultaneously, a CABI must be available to
visually inspect each excavation location (i.e., utilize multiple CABIs).
• The CABI(s) will be on site at all times that RACS is being removed to ensure that no visible
emissions are generated at any time during soil-disturbing activities. Additionally, the CABI
will verify that the soil moisture is sufficient during removal to suppress dust, and to ensure
that the material is adequately wet. If visible emissions are observed, then work practices
will be modified.
• Stockpiled soils will be stabilized using the application of water or magnesium chloride,
and/or by covering with overlapped poly sheeting or appropriate cover/stabilization.
7.2.2.2 Wind Break Barriers
As needed, wind break barriers should be constructed prior to commencement of removal activities,
and constructed of materials appropriate to site conditions. Ultimately, wind break barriers will be the
responsibility of the contractor. It is recommended that the wind break barriers be relatively portable
and adequate to minimize soil dispersal from the work area. The wind break barriers will be placed to
completely encompass the work area and loading area, as this will assist to prevent uncontrolled access
to the work area by unauthorized personnel during and after work shifts.
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7.2.3 RACS Disposal Procedures
7.2.3.1 Mechanical Removal/Disturbance of RACS from a Regulated Work Area
• Removal and disturbance of RACS will be conducted utilizing a direct-load system. RACS and
its associated required removal quantities will be removed adequately wet and transported
directly to DADS. Trucks will be prepared prior to loading by installing at least one leak tight
6-mil layer of poly as a liner (for non-friable RACS), or at least two layers of leak tight 6-mil
poly (for friable RACS). The liner(s) will be installed such that under normal conditions, it
(they) will not rupture during loading, transportation, and disposal. The poly liners will be
sealed at the opened ends for transport with mechanical fasteners (i.e., tie wire, zip-ties,
etc.).
• The project will have the option for all loads, based on continuous visual inspection and
documentation by a CABI, to be determined to contain less than one percent (by volume of
the load or container) of friable RACS, non-friable RACS or assumed ACM debris. In these
cases, the loads shall be packaged and disposed of with one leak tight 6-mil layer of poly as a
liner. If debris is assumed to be ACM, continuous CABI visual inspection is still required to
determine if the amount of RACS remains below 1% of the disposal load.
• An area to load the trucks with RACS will be prepared as close to the RWA as possible,
allowing safe access in and out of the site. A layer of 10-mil poly will be placed on the
ground as a loading pad to capture potentially spilled RACS and immediately cleaned or
replaced if any spillage or damage to the liner occurs.
• Standard erosion control BMPs must be established by the contractor to prevent
stormwater run-on/off for the duration of the loading and transportation activities.
• Spill prevention measures, as outlined in CSWR §5.5.7(G), will be incorporated during
loading of the RACS to prevent cross-contamination of adjacent areas. Specific measures
include;
o Protect surfaces of loading, transport or container equipment not meant to be in direct
contact with RACS materials. Should these surfaces come into contact with RACS, they
shall be decontaminated per section 7.2 of this standard operating procedure;
o Do not overfill the excavator or loader bucket and return the bucket to a closed position
prior to moving from the loading point;
o Replace protective coverings when worn or damaged in order to prevent breaches;
o Control runoff in order to prevent cross contamination outside of the RWA from water
containing asbestos.
• Spilled RACS shall be treated as an RWA and cleaned up immediately in accordance with
CSWR § 5.5.7 (J). It will not be allowed to dry out or accumulate on any surface. The
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Department’s Hazardous Materials and Waste Management Division shall be notified,
through the spill reporting hotline, in the event that spills of RACS cannot be cleaned up
within 24 hours of spill identification.
o Where there are breaches in ground coverings that have the potential to allow water
contaminated with asbestos to impact the material below the covering or surfaces that
are contacted by asbestos-contaminated water, a minimum of three (3) inches of soil, or
other matrix material, shall be removed.
o If ground coverings are placed on top of a durable surface such as concrete or asphalt,
the surface shall be decontaminated using wet methods, followed by CABI inspection
that all soil and debris has been removed from the surface.
o Rinsate, runoff, or any other water that has come into contact with RACS shall be
considered to be asbestos contaminated water and shall be collected. However it
cannot be for discharge to a sanitary sewer or other Department-approved disposal
facility. It may be re-applied to RACS that will be stabilized and managed under this SOP.
o Surfaces that are contacted by asbestos contaminated water can be permanently
stabilized as per Section 5.1.4 of this standard operating procedure.
• Trucks carrying friable RACS (friable material over 1% by volume of the disposal load) must
be labeled in accordance with the requirements of CSWR §5.5 using one of the following
legends in type at least five inches tall:
CAUTION CONTAINS ASBESTOS
AVOID OPENING OR BREAKING CONTAINER BREATHING ASBESTOS IS HAZARDOUS TO YOUR HEALTH
DANGER CONTAINS ASBESTOS
AVOID CREATING DUST CANCER AND LUNG DISEASE HAZARD
• Non-friable RACS will be labeled “Asbestos, Danger” along with the name of the generator
during transport.
• The contractor will be responsible for Department of Transportation protocols and labeling
for transportation of RACS.
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• It is likely that an excavator or front-end loader will be utilized for RACS removal,
disturbance, management, and loading. During all soil-disturbing activities involving RACS,
adequate wetting of soils will be performed. At least one water hose operator is required at
each excavation, and other means may be employed to ensure that RACS is adequately wet
(e.g., misting bars, additional hose operators).
• The equipment operator(s) will load the RACS directly into the pre-lined truck; the truck
drivers will not be allowed to exit the trucks during loading operations and will be required
to keep their windows closed and air handling systems off while their trucks are being
loaded.
• The excavation bucket will not be filled greater than 2/3 its capacity to avoid overfilling and
spilling.
• The CABI will continuously observe excavation and loading operations to verify that
adequate wetting has taken place and that no visible emissions occur, and that compliance
to this standard operating procedure is adhered to.
• During mechanical removal, if the CABI observes solid waste material (e.g., Non-Suspect
material as described in Section 4.1), with no visible evidence of suspect ACM, and there is
sufficient quantity, the CABI and contractor may elect to segregate this material for disposal
as non-ACM.
7.2.3.2 RACS Removal Quantities
The extent of removal quantities differs depending on where the RACS disturbance is taking place as
follows:
• When RACS is being removed from the surface – Wet and remove all RACS and its
associated six-inches in all directions, plus a minimum of six inches of soil or other matrix
material, in all directions from the last occurrence of visible ACM with CABI confirmation
that the visible extent of RACS has been removed (i.e., removal of visible ACM plus a
minimum 12-inches of soil in all directions).
• When RACS is being removed from the subsurface – Wet and remove all RACS and its
associated six-inches plus a minimum of three linear feet of soil or other matrix material, in
the direction of planned excavation with CABI confirmation that the visible extent of RACS
has been removed.
7.2.3.3 Off-Site Disposal of RACS
It will be the responsibility of the contractor to direct the schedule of transportation of RACS to DADS.
When loaded, each truck will be assigned a waste manifest to serve as the shipping document for that
load. Documentation stating that the soil originating from the project shall not be used as a daily cover
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or sold as clean fill will accompany each load of RACS removed from the project. DDPHE will coordinate
the waste profile and obtain waste manifests if requested.
RACS will be transported to DADS. Disposal of RACS will be conducted while adhering to CSWR §5. The
landfill processes will be followed, specifically regarding notification, profiling, and on-site disposal.
Disposal of Non-RACS will require notification to the landfill that the material to be disposed contains
Non-RACS, and based on the DADS requirements, the material will be handled accordingly (e.g., unlined
trucks, single-lined trucks). Special precautions shall be undertaken during the management of non-
RACS to prevent the material from being turned into RACS (i.e. being rendered friable).
7.2.4 Wind Speed Monitoring
Periodic wind speed measurements will be taken during RACS disturbance within each RWA by an AMS
or CABI at least once per every half hour. This frequency will be increased at the AMS’s or CABI’s
discretion when it has been determined that wind conditions may be approaching threshold limits, and
during wind gusts. It will be the responsibility of the AMS or CABI’s to take and record all wind speed
measurements onto the daily logs. All wind speed measurements will be taken within the work area in a
location deemed representative of the area. The following are conditions where work will be shut down
and started:
Shut down Conditions – RACS disturbance operations should immediately and temporarily cease when
one or more of the following conditions have been met:
• Any wind gust reaches or exceeds 20 miles per hour (mph) as determined by hand-held
instruments
• Sustained wind speeds reach or exceed 12 mph averaged over a 10-minute period
• Winds produce visible emissions or create movement of dust or debris in or near the work
area or loading area
• Winds impact any engineering controls and prevents them from functioning as designed
• During wind-related project shutdowns, other work not related to RACS disturbance may
continue
Startup Conditions – RACS disturbance operations may resume after all the following conditions have
been met:
• All wind gust readings drop below 20 mph for a period of 20 minutes as determined by
hand-held instruments
• Sustained wind speeds are below 12 mph averaged over a 20-minute period
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• Winds no longer produce visible emissions or create movement of dust or debris in or near
the RACS disturbance area
• Winds are not impacting the ability of engineering controls to work as designed
7.2.5 Air Monitoring
CDPHE will require minimum air monitoring when suspect or confirmed ACM/RACS is being disturbed
within a RWA, after the second consecutive day of RACS management. An appropriately trained and
certified AMS must perform the air monitoring activities at the project. The CABI will characterize debris
and air monitoring requirements will be made by the AMS based on the CABIs identification of the
debris and applicable regulations. The CABI and AMS can be the same person if she/he meets the CABI
and AMS requirements in Section 3.3. Ideally, the CABI and AMS will be the same person.
Air monitoring samples will be collected by the AMS using the procedures outlined below. All air
samples will be collected and analyzed in accordance with CSWR §5.5 – Appendix 5A.
7.2.5.1 Air Monitoring Matrix Tables
Personnel Monitoring and RWA Perimeter Sampling shall be performed in accordance with the following
air-monitoring matrix tables:
Table 3 Removal/Disturbance (by hand or hand-held tools) of Non-Friable RACS
Monitoring Type
Sample Frequency
Duration Analysis
RWA Perimeter Monitoring
None Not Applicable Not Applicable
Table 4 Removal/Disturbance (by hand or hand-held tools) of Friable RACS
Monitoring Type Sample Frequency Duration Analysis
RWA Perimeter Monitoring
Four samples at the perimeter of the RWA, at the points of the compass.
Ongoing after the 2nd day of
RACS disturbance
PCM and Transmission Electron Microscopy (TEM) sampling around RWA. Any sample with PCM results exceeding 0.01 fibers per cubic centimeter (f/cc) must be analyzed by TEM.
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Table 5 Removal/Disturbance by Mechanical Means (Heavy Equipment) of Non-Friable RACS
Monitoring Type
Sample Frequency
Duration Analysis
RWA Perimeter Monitoring
Four samples at the perimeter of the RWA, at the points of the compass.
Ongoing after the 2nd day of
RACS disturbance
PCM and TEM sampling around RWA. Any sample with PCM results exceeding 0.01 fibers/cc must be analyzed by TEM.
Table 6 Removal/Disturbance by Mechanical Means (Heavy Equipment) of Friable RACS
Monitoring Type
Sample Frequency
Duration Analysis
Area of Disturbance Perimeter Monitoring
Four samples at the perimeter of the RWA at the points of the compass, and two downwind floater samples.
Ongoing after the 2nd day of
RACS disturbance
PCM and TEM sampling around RWA. Any sample with PCM results exceeding 0.01 fibers/cc must be analyzed by TEM.
7.2.5.2 Personnel Air Monitoring
Personnel monitoring will be the responsibility of the contractor, per OSHA requirements, and is not
directed by this standard operating procedure.
7.2.5.3 Required Preliminary and Area Air Sampling Protocol
• During the first five days of RACS disturbance/removal – All air samples collected are
required to be analyzed by PCM methodology. Additionally, a minimum of 25% of the
samples collected from each RWA shall be submitted for TEM analysis. The sample(s)
selected for TEM analysis shall have the highest PCM result(s) based on fiber concentration.
If all PCM results are Below Detectable Limit (BDL) for fiber concentration, then the
sample(s) selected for TEM analysis shall be determined by highest fiber count. If all
samples have no fiber counts, then no TEM analysis is required.
• After five days of RACS removal/disturbance with no asbestos detections by TEM analysis
– the frequency of analysis by TEM, on the highest 25% of PCM results(s), may be reduced
to once every five days of RACS removal/disturbance, or portions thereof, using the same
selection criteria as above. During the period of reduced frequency of TEM analysis, the first
occurrence of high winds, exceeding wind shutdown criteria (Section 7.2.4), or visible
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emissions, shall result in that day’s samples (25%) being submitted for TEM analysis. In the
absence of high-wind events or visible emissions the selected day for TEM analysis may be
random, as determined by the AMS.
• If at any time, a sample analyzed by PCM returns results greater than 0.01f/cc, that sample
shall then be analyzed by TEM as required by CDPHE.
• If there are any asbestos detections during the random once-every-five-days-analysis by
TEM, then TEM analysis shall be conducted for three consecutive days of RACS
removal/disturbance, or portions thereof. If there are no additional asbestos detections
during the three consecutive days of RACS removal/disturbance with samples submitted for
TEM analysis, then the frequency of TEM analysis may return to random, once-every-five-
days of RACS removal/disturbance.
7.2.5.4 Area Air Sampling
• Air samples will be collected continuously during all mechanical removal of RACS.
• Area monitoring shall consist of a minimum of four samples collected on the perimeter of
the RWA, at the four-compass points, and at appropriate intervals to provide representative
information regarding potential releases of asbestos fibers to the Adjacent Receptor
Zone(s).
• Two additional downwind floating samples will be required for mechanical
removal/disturbance of friable RACS. The samples shall be moved based on prevailing wind
direction and adjacent receptors.
• Additional samples shall be collected for large perimeter RWAs (greater than one (1) acre).
RWAs greater than one (1) acre shall require additional perimeter monitoring points be
added at a rate of one (1) sample for every 200 linear feet (or approximately each additional
¼ acre).
• Air monitoring is not required where RACS management activities will occur in areas where
there is no Adjacent Receptor Zone present according to the definition of an adjacent
receptor zone where access to the public can be controlled (i.e., an area of at least 150 feet
surrounding the RWA can be controlled allowing no public access).
7.2.5.5 Sampling Media
Air samples will be collected by drawing air through a 25-millimeter mixed cellulose ester filter, 0.8-
micron pore size, with an open-faced, long cowl using low-flow personnel sampling pumps. The flow
rate and the volume of the air passed through the filter will be determined based on the National
Institute of Occupational Safety and Health (NIOSH) 7400 (NIOSH, 1987) analytical method. Each pump
will be calibrated before and after the collection of each sample using a primary standard.
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7.2.5.6 Sample Analysis
Air samples submitted for Phase Contrast Microscopy (PCM) shall be analyzed according to NIOSH Method 7400 by a laboratory showing successful participation in the American Industrial Hygiene Association (AIHA) Proficiency Analytical Testing (PAT) Program or individual(s) certified through the AIHA Asbestos Analysts Registry (AAR) Program. Analysis of TEM air samples will be submitted to a National Institute of Standards and Technology (NIST) accredited laboratory using TEM in
accordance with CSWR §5.5 Appendix 5A (Appendix D).
7.2.5.7 Response to Laboratory Results
If an air sample analyzed by PCM indicates fiber concentrations over 0.01f/cc, that sample is then
required to be analyzed by TEM. If an air sample has concentrations of airborne asbestos fibers after
TEM analysis of personnel and/or work RWA samples, then the CDPHE will be notified immediately. The
work practices and engineering controls, through consultation with CDPHE, will then be modified to
reduce emissions. In the event that this should occur, the following actions shall take place:
• Excavation will immediately halt
• The source(s) of fiber release will be identified
• RACS management operations and engineering controls will be reassessed to safeguard that
additional fiber releases do not occur
• If asbestos fibers are detected in air samples:
o All soil-disturbing activities will immediately cease
o The source of fiber release will be identified
o An Emission Control Plan in accordance with Section 5.5.7 of the CSWR §5.5 will be
derived and submitted to CCOD and the CDPHE for review
o Soil disturbance shall not continue until the CDPHE provides verbal and/or written
authorization to proceed.
7.2.6 RACS Stockpiling
7.2.6.1 Stockpiling of RACS
If RACS, which must be removed from the project, is in a location with limited or no access for direct
loading into trucks, the material may be stockpiled on site if the conditions below are met in accordance
with CSWR §5.5:
• The accumulation of RACS cannot exist for more than 10 calendar days without the
approval of a RACS Storage Plan by CDPHE.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
38
• Stockpiled RACS shall be placed on a minimum of 6-mil poly or a minimum of three-inches of
soil, or other matrix material located under the stockpile which must be removed following
removal of all stockpiled material.
• Rinsate/runoff shall be collected, filtered to five-microns, and discharged to a sanitary sewer
(contractor must have appropriate authorizations) or re-applied to RACS that will be
stabilized and managed under this standard operating procedure.
• The RACS must be adequately wet during stockpiling.
• The stockpile shall be stabilized by polyethylene sheeting, geofabric, or a chemical stabilizer
demonstrated to be effective in the stabilization of RACS (e.g., magnesium chloride).
• The condition of the stockpile and cover sheeting/geofabric/stabilizer must be inspected
daily and no later than 12 hours following storm events.
• All damage to the cover sheeting/geofabric/stabilizer must be repaired or replaced
immediately upon discovery.
7.2.6.2 Transporting RACS to Stockpile
The following directives and RACS handling must take place during on-site transport of RACS to a
stockpile location:
• Driving speeds shall not exceed 12 mph while machine is moving RACS.
• Transportation equipment tires shall not contact RACS. If tires do contact RACS, the RACS
must be adequately wetted to prevent dust/emissions and all equipment surfaces that have
come into contact with RACS shall be decontaminated (Section 7.2.7).
• If the transport equipment tires come in contact with RACS:
o The haul road shall be managed as RACS and maintained to prevent dust or emissions
generation and if any RACS is visibly observed it is to be removed immediately, along
with the required six inches of surrounding soil and handled appropriately.
o Following completion of excavation and grading activities, the material used in
construction of the haul road as well as three inches of underlying soil will be removed
and managed in the same manner as the RACS.
o Water and runoff from the haul road shall be collected and filtered to less than five
microns (or applicable local requirements) and discharged to a sanitary sewer
(contractor must have appropriate authorizations) or re-applied to RACS that will be
stabilized and managed under this standard operating procedure.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
39
7.2.7 Decontamination Procedures
7.2.7.1 Heavy Equipment or Machinery Decontamination
Heavy equipment will be decontaminated prior to leaving a RWA in such a manner as to ensure that
residual soil and contaminants are removed and other hazards are not present. Heavy equipment
decontamination will include the following steps:
• Decontamination will occur within a waste container when possible, and if not will be staged
on 6- or 10-mil poly to prevent cross contamination or spills. This will include mechanical
removal by asbestos workers using shovels or other hand-held tools while wearing
appropriate PPE.
• Next, the equipment will be thoroughly cleaned with amended water and rags.
• All used rags and disposable PPE will be disposed of as asbestos waste and transported to
the landfill.
• It will be the responsibility of the CABI to make final visual inspections and a final
determination regarding the decontamination of equipment for release to other portions of
the project, or off-site.
7.2.7.2 Asbestos Worker Decontamination During RACS Disturbance in a RWA
A fully functioning decontamination unit or trailer will be utilized at the project whenever RACS
disturbance within a RWA takes place. The decontamination unit will be located within 100 feet of the
project, and as near the removal area as practical. The decontamination unit will consist of three
chambers, should have fully operational hot and cold running water adjustable at the tap, and a
functioning water filtration unit that will filter the waste water to five microns or less. Reuse of waste
water from personnel decontamination is prohibited. For disposal, waste water may not be discharged
to the sanitary sewer within the City and County of Denver. However, it may be added to RACS,
generated by the project, as part of RACS disposal procedures if it does not interfere with the
requirements of section 7.2.3 (RACS Disposal Procedures) of this SOP, and does not cause the load to fail
a paint filter test. Disposal of decontamination water from equipment must also follow the same
disposal protocols. In no event may decontamination water be discharged to any sanitary sewer, storm
sewer, ditch, gutter, or stream.
To prevent cross-contamination, asbestos workers will wear clean outer protective suits as they exit
from the work area(s) to the decontamination area. The asbestos workers will either double suit and
remove the exterior suit, or don a second clean suit over the single suit, within the work area prior to
moving out of the RWA to get to the decontamination unit. The decontamination unit should be utilized
by the asbestos workers each time they exit the work area(s).
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
40
7.2.7.3 Decontamination and Personnel Protection During Removal of RACS/ACM
Asbestos workers and equipment will be decontaminated on site; dirt and debris should not leave the
immediate work area. The following procedures can be modified by the CABI based on the potential
level of exposure:
• Decontamination of workers can consist of removal of disposable Tyvek® suites, gloves, and
boot covers. These PPE will be bagged, labeled, and disposed as asbestos waste.
• Decontaminate non-disposable personal items by removing visible soil and dust with damp
wipes or rags, or by use of a high efficiency particulate air (HEPA) filter equipped vacuum.
Place wipes and rags in a plastic bag and dispose along with RACS materials. If additional
clothing is available, clothes should be changed and potentially contaminated clothing
should be bagged separately from wipes and rags.
• Decontaminate hand equipment and tools by removing gross soils and dust, then washing
the equipment. Materials used for decontamination should be bagged and disposed along
with RACS materials. Equipment decontamination rinsate water should be collected and
filtered to five microns prior to disposal, or reused for wetting of asbestos contaminated
areas that will be removed.
Based on analytical results of suspect materials, if asbestos is present, decontamination materials should
be bagged and disposed of as asbestos waste at the Denver-Arapahoe Disposal Site or with RACS in
accordance with this plan. If analytical results indicate that no asbestos is present, bags (non-asbestos
waste bags) can be disposed as non-asbestos solid waste.
7.2.8 Work Area Clearance
It will be the responsibility of the CABI to provide final visual clearance of the work area following
completion of RACS disturbance/removal. The CABI will document locations, and other pertinent
information, onto the daily logs for work area clearance.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
41
8. Close-Out Report
The CABI will be responsible for maintaining complete documentation of the project in accordance to
C.S.W.R 5.5.7 (L). After RACS disturbance/removal actions are completed, a project close-out report will
be prepared for CCOD’s files. The project close-out report will include at a minimum:
• Property description and description of area(s) with RACS
• Description of soil-disturbing activities
• Description of field operations or submittal of daily logs (Appendix B)
• Air monitoring logs
• Description/results of asbestos sampling events, including sample locations
• Analytical results
• Disposal summaries and manifests
• Details of excavation profiles
• Description of capped material left in place and site plan showing the capped area(s)
• Photographic logs
• Personnel certifications
Copies of the project close-out report will be submitted to the CCOD Project Manager. Project close-out
reports for RACS management projects are not required to be submitted to CDPHE.
Environmental Quality Division Denver Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
42
9. References
CDPHE, 2008. “Regulation No. 8, Part B – Asbestos”, Colorado Department of Public Health and
Environment, Air Quality Control Commission, Denver, Colorado, January 2008.
CDPHE, 2014. “Deletion and Replacement of Existing Section 5.5 Regulations (Management of Asbestos-
Contaminated Soil) with New Section 5.5 Regulations (Management of Regulated Asbestos
Contaminated Soil (RACS)); the Addition of Appendix 5A (Sample Collection Protocols and
Analytical Methodologies) and the Associated Additions and Revision to Section 1.2 Definitions.”
Colorado Department of Public Health and Environment, dated August 19, 2014.
NIOSH, 1987. National Institute for Occupational Safety and Health (NIOSH) Method 7400 Entitled
“Fibers” published in the NIOSH Manual of Analytical Methods, 3rd Edition, second supplement,
August 1987.
OSHA, 1987. Occupational Safety and Health Administration (OSHA) Regulation “Asbestos”, 29 C.F.R.
Part 1910.1001, Appendix B (OSHA 1987)
Environmental Quality Division Denver’s Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
Appendices
Environmental Quality Division Denver’s Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
Appendix A CDPHE Approval Letter
Environmental Quality Division Denver’s Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
Appendix B CABI Work Day Documentation Form
Time Sampled Depth
Bulk Sample Log
Sample ID# Sample Location/Description Asbestos Content From Analytical
1E
Observation of Non-Earthen Material or the Appearance of Fill:
1F
Observation of Any Other Impacted Soils (Non-Asbestos Impacts):
1C
Description of Hand Removals (Assumed RACS or Analyzed To Be RACS):
1D
Friability of Suspect Debris Materials:
Description of Encountered Debris Materials and Practices
1A
Types of Debris Identified (List all materials, clarify depths of piles):
1B
Description of Suspect Debris Material (RACS/ Non-RACS):
CABI Documentation
Identify environmental hazards discussed at the safety meeting:
Location Description:
Description of Site Activities :
Equipment Used (Model Number):
Inspector Certification Number: Weather:
City and County of Denver
Certified Asbestos Building Inspector Work Day Documentation Project Name__________________________________________________
Inspector Name: Date:
DDPHE V1.0
Delineation of Work Area
Work Zones
Utility Identification
Haul Routes / Access
Equipment Mobilization
Emissions Controls
Fencing and Wind Barriers
Other:______________________________________
Page 1 of 4
Inspector’s Company/Affiliation:
No.
No.
No.
No.
Gust Max:
Time Wind Speed Direction Time Wind Speed Direction
7:00 12:00
7:30 12:30
8:00 13:00
8:30 13:30
9:00 14:00
9:30 14:30
10:00 15:00
10:30 15:30
11:00 16:00
11:30 16:30
Comments:
Details (provide information on corrective actions): 5B
Visible emissions observed?
If visible emissions were observed, was worked stopped?
Air Monitoring Information As Applicable
General Conditions
Items YES NO
Details of Wind Shut Down Event (If Applicable):
5A
Were work conditions maintained below stoppage requirements?
Daily Wind Speed Sustained High:
Details (Provide Prevailing Wind Direction and 30-Minute Readings):
Spill Response
Items YES NO
4
Details (provide information on corrective actions):
Engineering and Administrative Controls
Items YES NO
3Details: (provide detailed description of any deficiencies)
2BDetails:
2A Details:
Decontamination
Items YES NO
RACS Management Detail
Have all equipment surfaces in contact with RACS been decontaminated?
Have workers conducted personal and equipment decontamination in accordance with applicable procedures?
Onsite Staging, Stockpiling, & Storage of RACS
Annual Awareness Training for Regulated Work Area Personnel
Annual Awareness Training for Non-Regulated Work Area Personnel
Page 2 of 4
Start Time Stop TimeTotal
Minutes:Flow Rate
Start:Flow Rate
Stop: Volume f/cc
No.
No.
8B
Contractor Monitoring
Items YES NO
Sample Location
Air Sample Log
Sample ID#
Were samples compromised in any way?
Have excavation and loading activities been conducted in accordance with applicable procedures?
8D
Have appropriate samples been collected to confirm ACS has been removed?
Details:
8C
Details:
Has visible material and associated soils been removed?
Details:
7
Is contractor working in the regulated work area conducting personal monitoring?
Details:
Are work practices conducted in accordance with the project MMP and State regulations?
8A
Work Practices and Completion
Items YES
Have loading and transportation requirements been met?
NO
Details:
Details (Pump Calibration Method):
6C
Is there an adjacent public receptor zone within 150 ft. of a Regulated Work Area?
Details (Location):
6B
Has the pump been calibrated?
No disturbance to sampling equipment or power source?
Perimeter Monitoring
6A
Adequate perimeter sampling points based on test area?
Details:
Page 3 of 4
CABI Field Inspector Name
Picture 1 Picture 2
Picture 4
Provide at least 4 Photos From Daily Operations Where RACS Management Is Being Done
Picture 3
Soils Disposition
9A
Where did the soil originate (depth, specific area)?
9B
Temporary or final disposition of soil (where on-site or disposed)?
9C
Method of material movement (What type of truck and loading)?
ASSOCIATED PHOTOS
Comments:
How many cubic yards of soil excavated during shift? (0 - 10000 yds.)
During RACS Management Operations, Include a Map of RACS Management Location(s) with this Documentation
Date
Page 4 of 4
Environmental Quality Division Denver’s Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
Appendix C Notification of Planned Soil Disturbing
Activity
4300 Cherry Creek Drive S., Denver, CO 80246-1530 P 303-692-2000 www.colorado.gov/cdphe
Jared Polis, Governor | Jill Hunsaker Ryan, MPH, Executive Director
A map, figure, or drawing, to a recognizable engineering scale, depicting the project area(s) must be submitted with this form. The form, plan (if applicable), and depiction of the project area, can be emailed to: [email protected]; or, mailed to: Colorado Department of Public Health and Environment, HMWMD-B2 Attn: Brian Long, Solid Waste Compliance Assurance Unit, see address below.
Date and time reported:
Planned management Start date: Estimated duration:
Unexpected discovery (submit within 24 hours of discovery) Discovery date and time: Estimated duration:
Description of planned soil-disturbing activities: Description of activities resulting in RACS discovery/disturbance:
Description of any access and/or emission control measures already implemented at the site:
Description of type and quantity of RACS discovered/disturbance:
This is an EMERGENCY management event (submit this form within 24 hours of RACS discovery, and comply with the Minimum Standards to the extent possible during initial management, and fully comply within 48 hours) Detail the nature of the emergency (e.g., repair to an active utility line):
Check the box to indicate which management approach will be utilized on this project:
Project Specific RACS Mgmt. Plan
Submit PSRMP for Division review and approval with this form at least 10 working days prior to commencing RACS disturbing activities.
RACS disturbance shall not commence until the PSRMP is approved. However, the standard requirements from Section 5.5.7 of the Solid Waste Regulation may be used in the interim after the required notice.
Standard Operating Procedures
Has the Division approved SOPs for this project?
Yes, include the name of the SOP here:
Notification shall be submitted to the Division prior to commencing RACS disturbing activities.
No, submit SOPs for Division review and approval with this form at least 30 calendar days prior to commencing RACS disturbing activities.
Remediation Plan
Submit remediation plan for Division review and approval at least 45 calendar days prior to commencing RACS disturbing activities. Remediation shall not commence prior to plan approval.
Standard Requirements
The standard requirements of RACS management are found in Section 5.5.7 of the Solid Waste Regulations. Notification shall be submitted to the Division prior to commencing RACS disturbing activities.
Risk Based Approach
Submit a site-specific risk assessment work plan for Division review and approval with this form prior to commencing RACS disturbing activities. RACS disturbance shall not commence until the plan is approved.
Please indicate which program this project will take place under: Solid Waste (general) / Voluntary Cleanup Program (VCUP) / Hazardous Waste Corrective Action (RCRA) / Federal Facilities or CERCLA / Don’t Know
Contact person for entity performing soil-disturbing activity:
Organization, company or agency:
Email: Phone:
Name of property owner/operator:
Owner/operator contact (if different):
Email: Phone: Ext:
Location of property: (Street address or other location description)
Street Address:
County: City: Zip:
General site description:
Received by: Date:
Dedicated to protecting and improving the health and environment of the people of Colorado
NOTIFICATION OF REGULATED ASBESTOS CONTAMINATED SOIL (RACS) DISTURBANCE
Environmental Quality Division Denver’s Department of Public Health & Environment
Regulated Asbestos Contaminated Soil Standard Operating Procedure
Appendix D Sample Collection Protocols and Analytical Methodologies
CSWR §5.5 – APPENDIX 5A SAMPLE COLLECTION PROTOCOLS AND ANALYTICAL METHODOLOGIES
1.0 Purpose
(A) The purpose of this appendix is to establish standard sample collection requirements and analytical methods and procedures for use in identifying and quantifying asbestos fibers in air, bulk material, and environmental media such as soil or ash.
2.0 Sample Collection Requirements
(A) The following sample collection requirements shall be followed when collecting samples for the purpose of determining the applicability of Section 5.5, and when collecting samples necessary to comply with the requirements of Section 5.5. Remediation plans submitted in accordance with Section 5.5.6 shall include a site specific sampling and analysis plan that incorporates the sample collection methodologies and analytical procedures in this Appendix, or proposes alternatives, and include site specific clearance criteria.
2.1 Bulk Samples
(A) Bulk samples shall be collected, in a manner sufficient to determine whether the material is asbestos-containing material (ACM) or not ACM, from each type of suspect ACM. Bulk samples shall be collected by a State of Colorado certified Asbestos Building Inspector (CABI). In the absence of bulk sample collection, any suspect ACMs must be assumed to be ACMs.
(B) Bulk samples shall be collected by homogenous type based on color, pattern, texture, thickness, associated materials, or by other identifying characteristics. Additionally, the quantity and location of a suspect material shall be used to determine the number of bulk samples required to characterize the asbestos content of each homogeneous suspect material. For the purpose of determining that a homogeneous suspect material does not contain asbestos, a minimum of three (3) bulk samples shall be collected from the homogeneous material unless there is insufficient material to constitute three (3) samples. If one of the collected samples of a homogeneous bulk material is determined to be ACM, then the homogeneous material shall be considered ACM.
2.2 Soil Samples
(A) Samples collected to determine asbestos content in soil shall be ten (10) point aliquot composite samples collected from a maximum area of 1,250 square feet (representing 0-6 inches beyond the exposed surface) or a maximum volume of forty (40) cubic yards. Individual aliquots shall be approximately 1/10 of the entire sample volume. At each aliquot location approximately one (1) tablespoon of soil shall be collected. The total volume of the ten (10) aliquots should equal roughly a half cup. The total collected sample volume should be greater than one quarter (¼) cup, but should not exceed one cup. Aliquot locations shall be randomly selected but shall be representative of the entire sample area or volume (to be inclusive of the interior of soil piles in addition to the surface). However, aliquots shall be co-located with any areas where friable ACM was formerly present. All samples collected to determine asbestos content shall be collected by a CABI.
(B) Sampling for clearance purposes of any exposed horizontal or vertical surface
shall have the following additional requirements:
1) The aliquots of a clearance sample shall not be collected until after the RACS, and the required amount of associated material, has been removed.
2) A visual inspection shall be performed and passed (i.e., no visible ACM
present) by a CABI prior to the collection of soil samples. Visual inspections shall include the following:
a) The area to be cleared shall be designated before the visual
inspection; and b) Former locations of friable materials shall be designated; and c) The surface being inspected shall be dry enough to allow identification
of suspect ACM; and d) The visual inspection shall be conducted in adequate lighting; and e) The area to be cleared shall be free of visual impediments (e.g. snow
cover, plastic sheeting, standing water, etc.); and f) At a minimum, the area to be cleared shall be inspected in at least two
(2) perpendicular directions; and g) Single or multiple inspectors may be used to perform a visual
inspection and clearance. However, a single inspector shall not
visually inspect more than a five (5) foot width with each pass [i.e. for a clearance area that is 25’ x 50’ a single inspector would be required to make at least five (5) passes in one direction (25’ length) and at least ten (10) passes in the other direction (50’ length)]; and
h) Detailed close examination of the area being cleared is required. The inspector(s) should use limited invasive inspection techniques, such as periodically sifting the surface being cleared and closely inspecting the disturbed area.
3) If sidewalls with six (6) inches or greater of vertical height are present, independent ten (10) point aliquot composite samples shall be collected from each of the sidewalls and the floor of the excavation.
2.3 Ash Samples
(A) Ash that contains, or is comingled with, suspect ACM and/or construction and demolition debris shall be considered to be RACS unless the ash is sampled, and analysis demonstrates that the ash is not RACS. Representative samples of each type of ash materials shall be sampled and analyzed in the same manner as soil (including area/volumetric limitations of sampling). Ash samples shall be collected by homogenous strata, location, content of other surrounding material, or other observations indicating heterogeneity of the ash present. All samples collected to determine asbestos content shall be collected by a CABI. In the absence of suspect ACM or construction and demolition debris, and in the absence of documented evidence of non-visible asbestos, ash material may be treated as non-RACS.
2.4 Cross Contamination Prevention
(A) All sample collection equipment shall be decontaminated in a manner sufficient to prevent cross contamination between individual samples or individual composite samples. Decontamination is not required between the collection of aliquots comprising a single composite sample.
2.5 Air Samples for Standard RACS Management
(A) Air samples shall be collected by drawing air through 0.8-micron (µm), 25-millimeter (mm), mixed cellulose ester (MCE) filters, using an open-faced cowl extension oriented face down at an angle of 45°. Sample flow rate shall be between 0.5-10 liters per minute depending on the anticipated duration of sampling and the specified detection sensitivity. The air sampling equipment
shall be run until the minimum volume required is collected for each sample. However, if the minimum air volume required by the method, and/or to reach the required analytical sensitivity, being utilized cannot be met, the State of Colorado trained and certified Air Monitoring Specialist (AMS) shall request that the laboratory prepare the sample using an indirect preparation method, for TEM presence/absence analysis. Air samples shall be collected at a height that is representative of the disturbance activity taking place. However, air samples shall be located at a height between three (3) feet above the ground surface but not to exceed twenty (20) feet above the ground surface. Air samples shall be collected by an AMS.
2.6 Air Samples for Risk-Based Air Threshold Monitoring
(A) Air samples shall be collected by an AMS. Air monitoring shall be conducted during each partial or full day of soil management activities using fixed and mobile monitors as follows:
1) A minimum of four (4) samples shall be collected for each regulated work
area (RWA). 2) For the purpose of determining the number of samples necessary, each
RWA shall be divided into four (4) equal quadrants. A minimum of one (1) sample shall be collected for each quadrant with an adjacent receptor zone.
3) If an RWA is greater than one (1) acre, one (1) additional sample for each quadrant with an adjacent receptor zone shall be collected and analyzed for each additional one quarter (¼) acre in RWA surface area.
4) Samples shall be located along the RWA perimeter, between the RWA and each adjacent receptor zone. Samples shall be placed between the RWA and any fixed adjacent receptor(s). In the absence of fixed adjacent receptors, sample placement shall be at the AMS’s discretion.
5) The sample volume shall be the minimum necessary to meet analytical sensitivity.
6) Samples shall be collected by drawing air through 0.8-micron (µm), 0.25-millimeter (mm), mixed cellulose ester (MCE) filters, using an open-faced cowl extension oriented face down at an angle of 45°.
3.0 Analytical Requirements
(A) The following analytical methods shall be used to evaluate the presence of asbestos and/or to determine asbestos content when analyzing samples for the purpose of determining the applicability of Section 5.5, and when analyzing samples collected in accordance with Section 5.5:
3.1 Bulk Samples
(A) Samples of suspect ACM shall be analyzed by polarized light microscopy (PLM), according to United States Environmental Protection Agency (USEPA) Method EPA/600/R-93/116 or equivalent method, to determine if any asbestos fibers are present. If the asbestos content of a sample is estimated to be 1% asbestos or less, but greater than 0%, by a method other than point counting (such as visual estimation), the determination shall be repeated using the point counting technique with PLM. Alternatively, the material may be assumed to be ACM. Analysis shall be conducted by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory.
3.2 Soil Samples and Ash Samples
(A) Prior to preparation of a soil or ash sample, bulk materials shall be separated from the soil or ash sample for independent analysis. Any bulk materials identified in a soil or ash sample that contain any amount of asbestos shall be reported as independent layers of the whole sample. The samples shall be adequately prepared (crushed and dried) to facilitate stereomicroscopic analysis by the laboratory. The goal of the preparation process should be to produce dried conglomerates of approximately one eighth inch (1/8”) to one quarter inch (¼”) size. Rock and/or stone material does not need to be crushed (this process is not intended to be homogenization). Soil and ash samples shall be analyzed by PLM according to USEPA Method EPA/600/R-93/116 to determine if any asbestos fibers are present. Analysis shall be conducted by a National Voluntary Laboratory Accreditation Program (NVLAP) accredited laboratory. During the stereomicroscopic analysis (10X – 50X) of the soil/ash sample the analyst shall sift through the sample at a rate of approximately one (1) tablespoon per minute. At the end of the stereomicroscopic analysis the sample shall be agitated or shaken as a final check for asbestos prior to the preparation of PLM grab mounts. At no time during the stereomicroscopic analysis shall a sub sample be collected. The entire sample shall be analyzed and the results reported. If no asbestos was identified by PLM after the initial stereomicroscopic examination, then three (3) random grab mount preparations shall be analyzed by PLM to determine if the sample is none detected for asbestos content. If any asbestos is found by the laboratory it shall be reported even in the absence of a second detection (i.e. there does not need to be a second detection to qualify a trace level of asbestos in the sample). Quantification of asbestos content shall be based on the entire sample volume, and be reported as such.
3.3 Air Samples for Standard RACS Management
(A) Air samples submitted for Phase Contrast Microscopy (PCM) shall be analyzed according to NIOSH Method 7400 by a laboratory showing successful participation in the American Industrial Hygiene Association (AIHA) Proficiency Analytical Testing (PAT) Program or individual(s) certified through the AIHA Asbestos Analysts Registry (AAR) Program.
(B) Air samples submitted for Transmission Electron Microscopy (TEM), for which
quantification of asbestos is desired, shall be prepared and analyzed according to the standard Asbestos Hazard Emergency Response Act (AHERA) method (AHERA; 40 CFR Part 763, Subpart E, Appendix A). All TEM analysis shall be performed by a NVLAP accredited laboratory. If a presence/absence analysis is desired, the analysis shall be performed using the AHERA method modified in the following manner:
1) A minimum of two (2) preparations shall be prepared and utilized for each
sample. 2) Analysis shall be conducted on a minimum of four (4) grid openings or
until three (3) or more structures are identified, whichever comes first. 3) Any structure (adhering to the AHERA counting rules) identified during
analysis shall be reported. a) Identification of less than three (3) structures shall be reported as
present. b) Identification of three (3) or greater structures shall be reported as
detected.
(C) Any air sample analysis that results in a “cannot be read (CBR)” determination from the analyst, or a “not analyzed (NA) or rejected” due to loose debris or uneven loading, shall be evaluated by the AMS to determine if a cause of the CBR or NA can be ascertained. If it is determined that the CBR is a result of overloading from airborne emissions, then the AMS shall request that the laboratory prepare the sample, using an indirect preparation method, for TEM presence/absence analysis.
3.4 Risk-Based Air Threshold Samples
(A) Air samples collected for TEM analysis shall be submitted to a NVLAP accredited laboratory. Samples shall be analyzed by TEM according to ISO Method 10312 with the following modifications for PCM equivalent (PCMe) structures:
1) An aspect ratio of 3:1 shall be used when counting structures greater than 5 µm in length, rather than the 5:1 ratio specified in the method.
2) A width range of 0.25 to 3 µm will be used when counting PCMe structures, rather than the 0.2 to 3 µm specified in the method.
3) A minimum of ten grid openings will be counted, rather than the minimum of four (4) grid openings specified in the method.
4) Calculations shall be made based on total fibers rather than primary fibers.
(B) The maximum number of grid openings (GOs) to be counted to achieve the specified analytical sensitivity shall be estimated as follows:
Number of GOs = EFA ÷ (AGO x V x S x CF)
where:
EFA = effective filter area (385 for a 25-mm filter) AGO = area of a grid opening (approximately 0.01 mm2; actual value to be provided by the analytical laboratory) V = volume of air sampled (in liters [L]) S = analytical sensitivity (structures per cubic centimeter [s/cc]) CF = conversion factor (1000 cc/L)
(C) Any air sample analysis that results in a “cannot be read (CBR)” determination
from the analyst, or a “not analyzed (NA) or rejected” due to loose debris or uneven loading, shall be prepared by the laboratory, using an indirect preparation method, for TEM presence/absence analysis.
3.5 Data Evaluation for Risk-Based Air Threshold Samples
(A) General requirements:
1) Samples collected for comparison to risk-based air thresholds shall be evaluated based on the average (mean) concentration over the exposure duration.
2) All valid data shall be used to calculate daily and ten (10) day rolling averages.
3) For all projects a minimum of three (3) samples per day must have quantifiable data (not CBR or rejected). If less than three (3) quantifiable analytical results are available then the daily average is invalid.
(B) Project days 1-9:
1) The results of the daily samples must be averaged to calculate a daily average for use in comparing to the risk based air threshold for days 1-9 of monitoring.
2) A ten (10) day average shall be calculated for days 1-9. The ten (10) day average shall be comprised of at least eight (8) valid daily average results. However, all valid data shall be used to calculate the ten (10) day average.
3) If the ten (10) day average exceeds the risk-based air threshold, engineering controls shall be adjusted to reduce the daily average.
4) The Department shall be notified within 24 hours if the calculations in paragraphs 1 and 2 above cannot be completed due to invalid data.
(C) Project days 10 and greater:
1) Starting on day 10, a ten (10) day rolling average shall be calculated and
compared to the risk-based threshold. 2) If average concentration trends indicate the risk-based air threshold will be
exceeded before project completion, engineering controls shall be adjusted to reduce the daily asbestos emissions.
3) If subsequent evaluation of average concentration trends indicates that the risk-based air threshold will still be exceeded before project completion, additional adjustments to engineering controls shall be made.
4) If changes in engineering controls are not effective in reducing airborne concentration trends such that the risk-based air thresholds can be met, consultation with the Department is required.
5) The Department shall be notified within five (5) working days if the averaged airborne asbestos concentration for the entire project exceeds the risk-based air threshold.
4.0 Documentation
(A) All of the following sampling and analytical documentation shall be maintained
during a project and available for Department review upon request. This documentation need not be submitted to CDPHE unless requested or as required in a project specific plan.
1) Documentation of bulk, soil, and ash samples shall include:
a. A description of the material being sampled including friability. i. For samples collected for characterization purposes also
include an estimate of the quantity of visible suspected RACS present.
ii. For samples of ash, also include a brief description of the ash layer, and any associated identifiable debris.
b. Name of person collecting the sample(s). c. Date and time of sample collection. d. Location of sample collection (a map, drawing, or diagram showing
sample locations in relation to the work area and surrounding area). e. The boundary/limits that are represented by the collected sample. f. Chain of custody documentation. g. Laboratory analysis reports. h. Log of characterized homogeneous bulk materials including
material descriptions, photographic documentation, and asbestos content.
2) Documentation of air samples shall include:
a. Name of person collecting the sample(s). b. Date and time(s) of sample collection. c. Locations of air sample collection. d. Any relocation of air samples. e. A map, drawing, or diagram showing air sample locations (initial
and relocations) in relation to the work area and the surrounding area.
f. Chain of custody documentation. g. Laboratory analysis reports. h. Explanation of any air sample malfunctions and any voided air
samples. i. Risk based air threshold concentration calculations.
j. Air sample data (flow rates, time of sampling, volumes, calibration method, etc.).
k. Wind speed measurements. l. Prevailing wind directions. m. Wind shut down events. n. Observations of visible emissions and responses.
5.0 Deviations from Sampling and Analysis Procedures
(A) Deviation from this sampling and analysis appendix shall only be allowed
upon consultation with, review by, and approval from, the Department.